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EPA Updates FY 2018-2022 Strategic Plan; is Criticized by Academics for Failure to Identify Susceptible Populations

On September 9, 2019, the U.S. Environmental Protection Agency (EPA) announced an update to its Fiscal Year (FY) 2018-2022 Strategic Plan. According to EPA’s announcement, the only part of the plan that has been modified is its language of the strategic goals. Aiming to better reflect EPA’s environmental and policy goals, EPA Administrator Andrew Wheeler stated that this “update helps us [EPA] more clearly articulate our goals and commitment to providing greater regulatory certainty to states, tribes, and local governments.” The update includes three updated goal statements as follows:

  • Goal 1: A Cleaner, Healthier Environment -- Deliver a cleaner, safer, and healthier environment for all Americans and future generations by carrying out the Agency’s core mission.
  • Goal 2: More Effective Partnerships -- Provide certainty to states, localities, tribal nations, and the regulated community in carrying out shared responsibilities and communicating results to all Americans.
  • Goal 3: Greater Certainty, Compliance, and Effectiveness -- Increase certainty, compliance, and effectiveness by applying the rule of law to achieve more efficient and effective agency operations, service delivery, and regulatory relief.”

On August 29, 2019, an article titled Population susceptibility: A vital consideration in chemical risk evaluation under the Lautenberg Toxic Substances Control Act was published in the PLOS Biology Journal. The article, written by academics, criticizes EPA for not identifying pregnant women, infants, children, families near industrial sites, and other susceptible and highly exposed populations in its risk evaluations. This lack of consideration for vulnerable populations, according to the article, is the lead cause of EPA’s future challenge to incorporate current scientific principles and address data deficits in the process of identifying, evaluating, and mitigating unreasonable risks. Given this challenge, Koman et al. urge EPA to act quickly to identify potentially highly exposed or susceptible populations and subpopulations, evaluate risks, and safeguard health through primary prevention.

©2020 Bergeson & Campbell, P.C.National Law Review, Volume IX, Number 256

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About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

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