When it comes to making a strong argument that the U.S. Environmental Protection Agency is overreaching when it comes to its proposed Integrated Risk Information System (IRIS) assessment for hexavalent chromium, listen to the people who supply our nation’s drinking supply.
In fact, the American Water Works Association had some of the strongest criticism of any group that weighed in.
“The AWWA is particularly concerned that the final toxicological review meets the needs of EPA’s Office of Water,” the group wrote to the EPA. “As currently drafted, the toxicological review implies a health concern for a concentration of Cr6 in water that is almost 3,000 times lower than the current total chromium maximum contaminant level and does so largely based on a single pair of animal studies where the lowest doses tested were nearly 300,000 times higher than the alleged level of concern in humans exposed via drinking water ingestion. AWWA has previously commented to EPA that a fit-for-purpose analysis was necessary.”
“EPA’s draft conclusions do not appear to be scientifically supportable."
In fact, many groups have pummeled the EPA’s 35 parts per trillion rule, saying the draft assessment “is not based on the best available science and is inconsistent with respected international authorities,” as the American Chemistry Council has said.
The Coachella Valley Water District went even further, saying they “believe it does not reflect the findings of numerous peer-reviewed studies, including those listed in the enclosure, that was completed following the 2008 National Toxicology Program (NTP) rodent study EPA has used to support the draft conclusions in the subject assessment.”
The CVWD says, “these incorrect assumptions result in a presumed Cr6 ingestion risk, as illustrated by the estimated oral cancer slope factor included in the subject assessment, that is orders of magnitude greater than what is supported using the more recent toxicological studies.”
It’s no surprise that the EPA is overreaching on this, as they have done many times in the last few years of the current administration. The rules will drastically affect surface finishers who use Cr6 in their processes and make it even harder to do business if these new regulations are approved.
Even the U.S. Chamber of Commerce had to speak out about the EPA’s proposed draconian measures.
"This disparity calls into serious question whether EPA’s analysis is scientifically supportable.”
“EPA’s draft conclusions do not appear to be scientifically supportable. EPA’s analysis appears to minimize the importance of the most recent high-quality research,” the USCoC says. “It concludes that there is essentially no safe level for certain exposures to Cr(VI) despite the overwhelming scientific evidence contradicting this conclusion and the conclusions of other authoritative bodies. This disparity calls into serious question whether EPA’s analysis is scientifically supportable.”
Suffice it to say, when the EPA starts putting parts-per-trillion rules into place, you have to wonder about where they are coming from these days. Are they trying to protect us from harm, or just taking a flame thrower to industries they don’t particularly like, such as the finishing industry?
Hopefully, common sense will prevail, but don’t hold your breath.
Tim Pennington is Editor-in-Chief of Finishing and Coating, and has covered the industry since 2010. He has traveled extensively throughout North America visiting shops and production facilities, and meeting those who work in the industry. Tim began his career in the newspaper industry, then wound itself between the sports field with the PGA Tour and marketing and communications firms, and finally back into the publishing world in the finishing and coating sector. If you want to reach Tim, just go 
