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                                                                                              November  10, 2020

U.S. Environmental Protection Agency's Integrated Risk

Information System (IRIS): Toxicity Assessment of Chemicals


The U.S. Environmental Protection Agency (EPA)
established the Integrated Risk Information System (IRIS)
program in 1985 to consolidate human health toxicity
assessments that the agency had prepared in order to
implement various pollution control statutes (e.g., Clean Air
Act and Clean Water Act). Specific incidents, such as the
1984 leak of methyl isocyanate from a Union Carbide
facility in Bhopal, India, reinforced the need for a better
understanding of human health toxicity from exposure to
various chemicals. Over time, findings from IRIS
assessments have informed many different agency actions,
including regulatory requirements that EPA has established
under various pollution control statutes. Given that these
actions may require regulated entities to incur significant
compliance costs and determine the extent of health
benefits, the process that EPA follows to conduct IRIS
assessments and the findings of such assessments have
received considerable attention.

EPA's  IRIS program is not authorized explicitly in statute,
but multiple pollution control statutes include general
research provisions intended for the agency to generate
information that may be useful in the implementation of
such statutes. Additionally, EPA continues to receive
annual appropriations to its Science and Technology
account that largely funds its research efforts, including the
IRIS program.

EPA  maintains a public IRIS website that provides more
than 560 assessments on a range of chemicals. EPA
completed more than 80% of these assessments before
1995. However, assessments completed more than 25 years
ago may still be relevant if no new information is available
to warrant a revision of the existing assessment.


EPA  staff managing the IRIS program select chemicals for
IRIS assessments through a prioritization process. This
involves soliciting internal input from EPA program and
regional offices on which assessments may be useful and
evaluating the extent to which resources and expertise are
available to complete the assessments. Changes in these and
other factors may also lead EPA to withdraw an initiated
assessment before it is completed. EPA began issuing an
IRIS Program  Outlook in December 2018 to provide
periodic updates on the development of IRIS assessments.

Given limited resources and many chemicals to assess, EPA
has decided to focus on a select number of assessments at
any given time. Assessments that examine multiple
pathways of exposure (e.g., ingestion, inhalation, or direct
contact) and potential health effects typically take many
years to prepare. In some instances, EPA may decide to


conduct an assessment with a more narrow scope, focusing
on a specific pathway of exposure or health effect. This
approach allows the agency to finalize an assessment more
quickly. EPA's selection of which chemicals to assess has
received scrutiny on occasion. For example, after some of
EPA's  announcements of upcoming IRIS assessments,
observers have raised questions about whether the agency's
plans reflect an appropriate assessment of high priorities.


Since 2016, EPA has included a preamble in each IRIS
assessment that summarizes the objectives and scope of the
IRIS program, general principles and systematic procedures
used in developing assessments, and the overall
development process and document structure. The preamble
is accompanied by the preface, which is chemical-specific
and describes procedures in the assessment that differ from
the general procedures described in the preamble.

In the preamble of each IRIS assessment since 2016, EPA
describes seven steps for developing IRIS assessments:

    Step 1. Draft development;
    Step 2. Agency review;
    Step 3. Interagency science consultation;
    Step 4. Public comment, followed by external peer
    review;
    Step 5. Assessment revision;
    Step 6. Final agency reviews and interagency science
    discussion; and
    Step 7. Post final assessment.

EPA  staff preparing IRIS assessments may revisit prior
steps of the process based on input from program and
regional offices, other agencies, peer reviewers, or the
public. The process, from start to finish for assessments
completed since 2013, has typically spanned at least five
years, with the ethylene oxide carcinogenicity assessment
taking 17 years. EPA now states that it aims to complete an
assessment within three years.

After selecting a chemical to assess and prior to developing
a draft assessment, EPA generally prepares a series of
documents that detail how the agency plans to develop the
draft. EPA practice is to issue each of these documents for
public comment, which may help to inform how the agency
performs the assessment. The first document that EPA
prepares for an assessment is the scoping document, which
describes the chemical being assessed, potential routes and


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