Setting the Record Straight on IRIS Reform Progress

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The Competitive Enterprise Institute published my paper this week on the Environmental Protection Agency’s Integrated Risk Information System (IRIS). This is a research program that assesses chemical toxicity, generating assessments that EPA program offices use to develop regulations under federal laws. As I point out in the paper, IRIS has a long history of sloppy research and lack of transparency, which the National Academies of Sciences pointed out back in 2011, along with recommended reforms. IRIS staff have supposedly been working to fix the program since then, but have by-and-large failed.

In a Greenwire story, Environmental Defense staffer Richard Dennison disputes my assertion that IRIS reform progress has been sluggish at best. The Greenwire story states that “a 2018 report from the National Academies found the program has made ‘substantial progress’ in implementing recommended reforms.” Dennison says that I “glossed over or omitted” this progress “in an effort to continue to demonize the program.”

In reality, my effort sets the record straight. The NAS “report” documenting such “progress” was basically a charade orchestrated by EPA staffers seeking to save IRIS and their fiefdoms therein. I addressed this reality in detail. Here is an excerpt from my paper:

Reform efforts supposedly have picked up pace since President Obama selected Kristina Thayer—a former contractor/employee of the left-of center Environmental Working Group, which has a long history of exaggerating risks and supporting regulations that raise prices and limit consumer choice—to take over the office in January 2017. Shortly before leaving office, Obama also selected Tina Bahadori to head the National Center for Environmental Assessment (NCEA), which houses IRIS within EPA’s Office of Research and Development.

In early 2018, President Trump’s budget proposed significant cuts and the Senate Omnibus reconciliation bill proposed IRIS elimination. Working to save the program, Thayer and Bahadori called for a NAS workshop and review. For a day and a half in February 2018, Thayer and Bahadori briefed the NAS panel on the procedural reforms and activities they were implementing. NAS released this review in April 2018. This time the EPA managed to get some modest praise for its reforms. EPA staff apparently wanted to use the NAS review to demonstrate that the IRIS has finally made some real progress, but a closer look suggests otherwise.

IRIS staff garnered some praise and avoided a critical review by keeping the scope of the NAS review extremely narrow. They asked the committee to assess only whether the “current trajectory of the program agrees with past recommendations of the National Academies” in 2011 and 2014. The NAS report explains further that the committee “was not asked to evaluate the overall value of the IRIS program,” and it “was not tasked with conducting a comprehensive review of the IRIS program.” In other words, all the NAS was asked to do was validate the efforts the EPA has undertaken to improve the process, not whether it finally achieved its goals or whether it had substantially improved its assessments.

The EPA got what it requested, as the 2018 NAS report appears very positive but actually says little. Of the 130 pages, about 90 simply republish EPA presentations and posters, and much of the rest includes background information, title pages, and appendices. Twelve pages provide a history of the issue. The report offers a few sentences of praise for some procedural reforms, but also points out that IRIS has still not achieved some basic goals. For example, IRIS has not even finalized a handbook outlining its process, which NAS asked for in 2014.

The 2018 NAS report may have helped IRIS program staff generate good press, but it raises the question of whether their limited process reforms have translated into sound assessments or improved productivity. That information is not part of the NAS report.

Read the full paper here.