Contact your House and Senate member TODAY and urge them to vote YES on Rep. Grothman’s amendment #96 that restricts funding for the EPA’s Integrated Risk Information System (IRIS) program.

Background

In 1985, the Environmental Protection Agency (EPA) created the Integrated Risk Information System (IRIS) Program in response to a growing demand for consistent information on chemical substances for use in risk assessments, policy-making and regulatory actions. The IRIS Program was intended to support EPA’s mission by identifying and characterizing the human health effects that may result from exposure to chemicals in the environment.

Characterizing risk involves integrating information on hazard, dose-response and exposure and the IRIS Program does not assess actual human health risk. EPA must rely on the best available and most relevant science as the foundation for its decision-making. EPA’s mission to protect public health and the environment is grounded in the public having confidence in the integrity of the assessments conducted by the Agency.

IRIS is not fulfilling that mission. 

Read the American Chemistry Council's letter to the House Appropriations Committee

Lacks Transparency 

The method by which substances are selected for IRIS hazard assessment remains unclear and there are no opportunities for stakeholders to provide input on IRIS assessment priorities. It continues to be a black box regarding how the chemicals under review by the IRIS Program will inform regulatory decision-making by the Agency. The IRIS Program has no specific number of hazard assessments that must be underway and the Program has consistently failed to meet its annual milestone progress score for completing IRIS hazard assessments. Additionally, there is no set timeline for completing an IRIS hazard assessment. While the Agency estimates a maximum of 3 years to complete an assessment, in reality, IRIS hazard assessments can take on average 5–10 years to complete.

Failure to Fully Address Peer Review and Stakeholder Recommendations 

The IRIS Program has yet to fully demonstrate implementation of the series of recommendations by the National Academy of Sciences (NAS) which included developing a clear set of criteria for judging the relative merits of individual mechanistic, animal, and epidemiologic studies for estimating human dose-response relationships.

Out of Step with Best Available Science and Methods 

The IRIS Program still fails to effectively or consistently utilize a weight-of-the-evidence process to identify, evaluate and integrate all available scientific evidence, including mode of action information and mechanistic data. This is necessary to derive scientifically defensible toxicity values that can be used by risk assessors to reach reliable conclusions regarding human health risk from chemical exposures. This is in contradiction to EPA’s 2005 Carcinogenicity Assessment Guidelines that clearly recommends considering mode of action in the evaluation of carcinogenicity. IRIS assessments are known to generate overly conservative values that have not fully evaluated the best available science and have even proposed toxicity values that are below those levels naturally produced by the human body. Since IRIS assessments do not undergo a “reality check” to ensure the values make sense, they can lead to unnecessary public alarm and lead to inaccurate risk management decisions.