Thank you, Madam Chair, and thank you to all the witnesses for being here today to discuss EPA’s IRIS program.

Over the last 10 years, numerous reports have been issued criticizing the IRIS program for its lack of transparency, improper scientific processes, and ineffectiveness in addressing the needs of EPA regional and program offices.  The flaws are well documented. 

Current EPA leadership is taking positive steps to address these issues, and I applaud their progress.   However, we have yet to see a completed assessment from the IRIS program that fully incorporates all the recommendations made in the last decade.  Unfortunately, that means there are numerous IRIS assessments in the database that are questionable, unreliable, and in some instances just plain incorrect.

Take IRIS’ assessment of ethylene oxide, which is used to sterilize medical equipment.  In fact, some medical equipment can’t be sterilized by any other chemical. 

In 2016, IRIS set an absurd risk value that is 19,000 times lower than the levels of this chemical that naturally occur in the human body.  Assessments like this one can have disastrous effects on the economy and human health if relied upon by government agencies in crafting regulation.

Accordingly, today’s hearing raises an important theme: how we characterize the risk of chemicals in the environment.  Unfortunately, there are too many government agencies, both national and international, that mischaracterize risk associated with chemicals.  These agencies, just like the IRIS program, have a history of identifying extremely conservative, even paranoid, levels of exposure that can be classified as carcinogenic. 

Another program with a poor track record of assessing risk is the International Agency for Research on Cancer, or IARC.  Unlike IRIS, IARC’s problems go beyond bad science.  IARC is plagued by a severe lack of transparency and accountability, as well as significant conflicts of interest.  But other parallels with IRIS exist. 

IARC assessments have led to the classification of things like red meat and coffee as being carcinogenic.  States like California adopt these assessments at face value and slap a warning on every product imaginable. 

The public promptly ignores these warnings because they know coffee will not give them cancer.  In the end, we are left with useless and ineffective regulations that only serve to waste taxpayer money.

Although the IRIS program does not have regulatory authority, it is important to note the consequences when government agencies mischaracterize risk.

Like I said, I am pleased the current administration is taking a thoughtful and meaningful look at how we characterize chemical risk.  I’m hopeful these efforts bear fruit. In the meantime, we will remain vigilant in ensuring that programs like IRIS are useful, transparent, and effective in meeting EPA’s core mission of protecting human health and the environment.