EPA Announces Experts Selected for Letter Peer Review of Draft Risk Evaluation for TCEP
Today, the Environmental Protection Agency (EPA) published the list of 10 scientific experts selected to review the 2023 Draft Risk Evaluation for Tris(2-chloroethyl) Phosphate (TCEP) under the Toxic Substances Control Act (TSCA). Biographies of these experts are available in docket EPA-HQ-OPPT-2023-0265 on www.regulations.gov and through the Agency’s TSCA Scientific Peer Review Committees website. This announcement follows a call for nominations of scientific and technical experts for the letter peer review issued in September 2023 and a call for public comments on the expert candidates in December 2023.
EPA will hold a virtual public meeting on March 5, 2024, to review the documents and draft charge questions being posed to the reviewers and address any questions from reviewers and the public regarding the scope and clarity of the questions. The meeting also gives the public the opportunity to ask questions about the documents with the letter peer reviewers present. Register here by March 1 to attend the meeting. The letter peer review is expected to begin on March 13, 2024.
EPA released the TCEP draft risk evaluation for public comment in December 2023. TCEP is a chemical historically used in paints and coatings, aerospace applications, fabrics and textiles, foam seating and construction materials, and is also found in a range of goods that are imported into the U.S. Although U.S. production of TCEP has decreased by about 99 percent since 2014, it is still used in the U.S. to make some paints and coatings, and also is used as a flame retardant and plasticizer for specific aerospace applications. TCEP has been linked to kidney cancer, as well as reproductive, neurological, developmental and kidney effects.
EPA’s draft risk evaluation found unreasonable risk from breathing or ingesting TCEP that comes out of textiles or other products and gets into indoor air. EPA also found infants and children may be at risk if they frequently mouth products containing foam, textiles or wood that contain TCEP for long periods of time, which may prove to be conservative assumptions that do not reflect real-world exposures. TCEP can also accumulate in fish if they live in a stream or other waterbody with high concentrations of TCEP. EPA found unreasonable risk for people eating fish taken from TCEP-contaminated water. These concerns are particularly notable for groups that eat higher quantities of fish, such as subsistence fishers and Tribes. Another subpopulation EPA included in its evaluation was infants exposed through human milk (e.g. breastfeeding), and EPA found that infants were at less risk than their mothers. EPA also found that TCEP presents unreasonable risk to the environment, specifically to aquatic organisms chronically exposed to TCEP through surface water and sediment.
EPA is using a letter peer review to obtain comments on the TCEP draft risk evaluation. As stated in EPA’s Peer Review Handbook, “a letter review takes place when EPA seeks individual written peer review comments from independent experts, typically in the form of correspondence to EPA from the peer reviewer… Each reviewer evaluates the draft technical work product independently without consultation with other reviewers. No collaborative or consensus peer review report is developed.” When EPA undertakes a letter peer review, it takes steps to ensure that letter peer reviewers only provide comments as individuals without consultation or conversation with other reviewers because such consultations or conversations could be subject to the Federal Advisory Committee Act.
The final selection of the reviewers depended upon the scientific expertise needed to address the letter peer review charge and obtaining a breadth and balance of different scientific viewpoints across the individual reviewers. EPA’s goal is to seek and obtain a balance of professional and scientific perspectives based on academic, clinical, industrial, and consulting (e.g., expert testimony) experiences.
Candidates were asked to submit confidential financial information (EPA Form 3110-48; Confidential Financial Disclosure Form), and fully disclose, among other financial interests, the candidate's employment, stocks and bonds, and where applicable, sources of research support. EPA evaluated the candidates' financial disclosure forms to assess whether there are financial conflicts of interest, appearance of a loss of impartiality, or any prior involvement with the development of the documents under consideration (including previous scientific peer review) before selecting the candidates.
EPA will use feedback received from public comments and the letter peer review to inform the final risk evaluation.
For additional information, please contact Dr. Alaa Kamel, Peer Review Leader, [email protected].