Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review (Federal Register Document ID: EPA-HQ-OAR-2018-0746)

The document is a formal statement signed by 271 experts supporting the US EPA's 2016 Integrated Risk Information System (IRIS) risk value for ethylene oxide. The signatories argue that the IRIS value represents the best available science and was developed through a transparent, peer-reviewed process. They specifically oppose the Texas Commission on Environmental Quality's (TCEQ) alternative risk value, claiming it underestimates cancer risk by 2000-fold, ignores evidence linking ethylene oxide to breast cancer in women, and lacks transparency. Additionally, the authors call for the EPA to consider cumulative health risks and environmental justice for marginalized communities living near industrial polluters.

• The signatories support the 2016 Integrated Risk Information System (IRIS) inhalation unit risk estimate for ethylene oxide, asserting it is based on the best available science and a rigorous, transparent process reviewed by federal agencies and independent experts.
• The experts oppose the Texas Commission on Environmental Quality (TCEQ) risk value for ethylene oxide, stating it estimates cancer risk to be 2000 times lower than the IRIS value and is not based on the best available science.
• The TCEQ risk analysis is criticized for excluding established evidence regarding the link between ethylene oxide and breast cancer in women and for using a statistical model that does not fit lymphoid cancer data.
• The process used by the TCEQ to develop its risk value is described as lacking transparency and failing to follow the established IRIS Process for Developing Human Health Assessments, specifically regarding the disclosure of technical documentation.
• The authors argue that the current regulatory system fails to protect public health because it does not account for the cumulative and synergistic effects of multiple hazardous pollutants experienced by residents in environmental justice communities.
• The EPA is urged to address disproportionate harms affecting historically marginalized groups, including Black, Latinx, Indigenous, immigrant, and low-income communities, in accordance with its commitment to environmental justice.

APA

Union of Concerned Scientists (2022). Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review (Federal Register Document ID: EPA-HQ-OAR-2018-0746). https://ucs-documents.s3.amazonaws.com/science-and-democracy/EPA-HQ-OAR-2018-0746-Letter-with-Signatures.pdf

Chicago

Union of Concerned Scientists. Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review (Federal Register Document ID: EPA-HQ-OAR-2018-0746). 2022. https://ucs-documents.s3.amazonaws.com/science-and-democracy/EPA-HQ-OAR-2018-0746-Letter-with-Signatures.pdf.

Wikipedia

{{cite press release |author=Union of Concerned Scientists |title=Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review (Federal Register Document ID: EPA-HQ-OAR-2018-0746) |date=24 March 2022 |url=https://ucs-documents.s3.amazonaws.com/science-and-democracy/EPA-HQ-OAR-2018-0746-Letter-with-Signatures.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{unionofconcernedscientists2022reconsideration, author = {{Union of Concerned Scientists}}, title = {{Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review (Federal Register Document ID: EPA-HQ-OAR-2018-0746)}}, publisher = {Union of Concerned Scientists}, year = {2022}, month = mar, url = {https://ucs-documents.s3.amazonaws.com/science-and-democracy/EPA-HQ-OAR-2018-0746-Letter-with-Signatures.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }