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Company Safety Data Sheets on New Chemicals Frequently Lack the Worker Protections EPA Claims They Include

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Company Safety Data Sheets on New Chemicals Frequently Lack the Worker Protections EPA Claims They Include
Pxhere

By Richard Denison

Readers of this blog know how concerned EDF is over the Trump EPA's approval of many dozens of new chemicals based on its mere "expectation" that workers across supply chains will always employ personal protective equipment (PPE) just because it is recommended in the manufacturer's non-binding safety data sheet (SDS).


The typical course has been for EPA to identify risks to workers from a new chemical it is reviewing under the Toxic Substances Control Act (TSCA), but then — instead of issuing an order imposing binding conditions on the chemical's entry onto the market, as TSCA requires — to find that the chemical is "not likely to present an unreasonable risk" and impose no conditions whatsoever on its manufacturer. This sleight of hand is pulled off by EPA stating that it:

expects employers will require and workers will use appropriate personal protective equipment (PPE) … consistent with the Safety Data Sheet prepared by the new chemical submitter, in a manner adequate to protect them.

We have detailed earlier the myriad ways in which this approach strays from the law, is bad policy and won't protect workers. But here's yet another gaping problem: When we are able to look at the actual SDSs — that is, when EPA has made them available and when they are not totally redacted — we are frequently finding that the specific PPE that EPA claims to be specified in the SDSs — and that EPA asserts is sufficient to protect all workers handling the chemical — is not in the SDSs.

EDF recently examined the SDSs for each of five new chemicals where EPA has declared them "not likely to present an unreasonable risk" and included the language I cited above. EPA has also included the five in a proposed Significant New Use Rule (SNUR) that would require companies to notify EPA if they intend to use a chemical in a particular manner that EPA has defined as a "significant new use." On Monday, EDF filed extensive critical comments on those proposed SNURs.

The reason we are focusing here on these chemicals is because, by law, EPA had to establish a rulemaking docket for the SNUR and place in that docket certain supporting documents pertaining to each new chemical. Among those documents is (supposed to be) the chemical's corresponding SDS.

Unfortunately, for two of the five chemicals (identified as P-18-0073 and P-19-0010, because the companies claimed their actual identities to be confidential), EPA failed to provide a copy of the SDS in its docket even though it is part of the documentation the company was required to submit to EPA. For another of the five (P-17-0239), the copy of the SDS EPA included in the docket is totally redacted — even though much if not all of its content comprises health and safety information not eligible for confidential business information (CBI) protection under TSCA and, for the remainder, there is no evidence EPA has reviewed and approved any CBI claims the company asserted for the SDS.

That leaves us with the SDSs for the remaining two cases (P-18-0048and P-18-0122), which are unredacted. Now we can compare what they specify by way of PPE to the specific PPE that EPA relied on in determining these chemicals are "not likely to present an unreasonable risk."

P-18-0048: Here is what the "not likely" determination document for P-18-0048 states:

Risks to workers: Reproductive toxicity via dermal exposure; corrosion to all tissues via dermal and inhalation exposures.

PPE EPA relies on: EPA identifies as "appropriate PPE" the use of "impervious gloves and a respirator." EPA goes on to state:

EPA expects that employers will require and workers will use appropriate personal protective equipment, including dermal and respiratory protection with an Assigned Protection Factor [APF] of 50, consistent with the Safety Data Sheet submitted with the PMN [premanufacture notice], in a manner adequate to protect them. (p. 6, emphasis added)

The associated SDS does recommend wearing "protective gloves," "suitable protective equipment," and "appropriate chemical resistant gloves." Its only reference to respiratory protection, however, is this:

[I]n the case of insufficient ventilation, wear suitable respiratory equipment.

Nowhere does the SDS specify use of a respirator with an APF of 50. The SDS is clearly not consistent with EPA's own description of it.

P-18-0122: Here is what the "not likely" determination document for P-18-0122 states:

Risks to workers: Lung toxicity via inhalation; irritation to skin, eyes, lung and GI tract.

PPE EPA relies on:

Risks will be mitigated if exposures are controlled by the use of appropriate PPE, including respiratory protection with an APF of 10. Risks could not be quantified for irritation hazards, but appropriate PPE, including impervious gloves and protective eye wear, would mitigate concerns. EPA expects that employers will require and workers will use appropriate personal protective equipment (i.e., impervious gloves, protective eye wear, and a respirator), consistent with the Safety Data Sheet prepared by the PMN submitter, in a manner adequate to protect them. (pp. 5-6, emphases added)

While the corresponding SDS does recommend certain types of gloves and safety glasses, it specifically states:

Other protective equipment is not generally required under normal working conditions.

The only mention of use of a respirator anywhere in the SDS is where an OSHA regulatory workplace standard is exceeded – which is clearly not the case here, as no such standards exist for the new chemical. Nowhere does the SDS specify use of a respirator with an APF of 10. Here again, the SDS is clearly not consistent with EPA's own description of it.

Other Recent Cases Found

This finding spurred us to look further at other "not likely" determinations and the corresponding SDSs. This is slower-going, because there is no electronically accessible docket. That's not only because EPA has not proposed a SNUR for other new chemicals to which it recently gave the green light; it's also because EPA has failed to comply with its own regulations requiring it to provide electronic access to all new chemical submissions it receives.

As we have described elsewhere, EDF has had no choice but to request the "public files" for these chemicals through EPA's Docket Center, which can take several weeks (they come by snail mail on a CD-ROM).

I looked at a number of recent new chemicals EPA has green-lighted for which we have received public files. In one case no SDS was provided in the public file, while in two others the SDS was there but again totally redacted. In some of the remaining cases the SDS recommended PPE that matched that EPA described in its "not likely" document, or at least came close.

But in other cases, there was not a match. Here are two examples:

P-19-0021/22: Here is what the "not likely" determination document for P-19-0021 and P-19-0022 states:

Risks to workers: Lung overload via inhalation.

PPE EPA relies on:

Risks will be mitigated if exposures are controlled by the use of appropriate PPE, including a respirator with APF of 50. EPA expects that workers will use appropriate PPE consistent with the SDS prepared by the PMN submitter, in a manner adequate to protect them. (p. 5, emphases added)

The associated SDS makes only this reference to respiratory protection:

Respiratory protection: Mist respirator, include single use respirator

Nowhere does the SDS specify use of a respirator with an APF of 50. The SDS is clearly not consistent with EPA's own description of it.

P-18-0212: Here is what the "not likely" determination document for P-18-0212 states:

Risks to workers: Systemic effects via inhalation exposure; portal of entry/contact effects to the eyes, lungs and skin following ocular, inhalation, and dermal exposures

PPE EPA relies on:

The risks and hazards identified will be mitigated if exposures are controlled by the use of appropriate PPE, including impervious gloves, respirators with an APF of at least 10, and eye protection. EPA expects that workers will use appropriate personal protective equipment (i.e., impervious gloves, respirator with an APF of at least 10, and eye protection), consistent with the Safety Data Sheet submitted with the PMN, in a manner adequate to protect them. (p. 5, emphases added)

The associated SDS makes this reference to respiratory protection:

Respiratory Protection: For operations where inhalation exposure can occur use an approved respirator. Recommendations are listed below. Other protective respiratory equipment may be used based on user's own risk assessment. Recommended respirators include those certified by NIOSH.
Recommended: Full Face Mask with a combination particulate/organic vapor cartridge.

Nowhere does the SDS specify use of a respirator with an APF of 10. The SDS is clearly not consistent with EPA's own description of it.

Conclusion

In each of these cases, EPA identified a particular type of respirator as necessary for its finding that the chemical is not likely to present an unreasonable risk, and in each case, EPA asserted that the corresponding SDS specified that type of equipment. But in fact, in each case, the SDS does not specify that type of respirator. EPA's decisions run counter to the actual evidence before the agency, and EPA has actually mischaracterized that evidence. That amounts to arbitrary decision-making. Practically speaking, this mismatch means that workers could follow the SDS to a T and be using a respirator that is not sufficient to protect them against the chemical's identified risks.

As we have noted before, EPA's reliance on SDS-recommended PPE flouts the law and falls vastly short of what TSCA requires EPA to do to protect workers. Amended TSCA requires EPA to issue binding orders to mitigate identified risks posed to workers by new chemicals, which it has identified in each of the cases we cite above. EPA's mere "expectation" that PPE will universally be available, used and effective is wholly insufficient to address the identified risks. The recommendations in an SDS are not binding on employers, neither on manufacturers nor on other companies downstream in supply chains. Failure to always use PPE or for it always to be effective is clearly reasonably foreseeable, and EPA is required to mitigate risks from "reasonably foreseen conditions of use" of a new chemical. PPE is the option of last resort under the longstanding Industrial Hygiene Hierarchy of Controls adopted by OSHA and embraced by the industrial hygiene community. Reliance on expected use of PPE shifts the burden of protection off of EPA and employers and onto the backs of workers.

Now, we find that even the PPE EPA identifies as necessary to be in an SDS in order to determine that a new chemical is not likely to present an unreasonable risk is frequently absent from the SDS. Even under its own flawed theories, EPA is utterly failing to protect workers from the risks of these chemicals.

How much farther under the bus will the Trump EPA throw American workers?

Richard Denison is a lead senior scientist with Environmental Defense Fund.

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Trending

Do you feel embarrassed due to the foul odor coming from your mouth? Or your oral hygiene isn't as good as before, and you are suffering from gingivitis (inflammation of gums)?

Well, these oral problems are skyrocketing, and even young people are suffering from oral issues that result in a lack of confidence.

It's common to change your toothpaste by seeing the TV commercials that claim to free you from bad breath or sensitive teeth, but these products don't always work.

Fighting oral issues isn't that easy, even if you religiously follow what your primary school teacher has taught, to "Brush two times a day!"

Well, there is a much-hyped supplement in the market that claims to help you fight all of these oral issues: The Steel Bite Pro.

Steel Bite Pro is an oral supplement that claims to cure bad breath and other such oral issues like sensitivity and gum problems.

But does the supplement really work, or is it just like the useless toothpaste that you tried before? Let's find out in this review.

Who Should Use Steel Bite Pro?

The best part about Steel Bite Pro is that anyone can use the supplement to get rid of oral issues. The supplement contains natural ingredients such as turmeric, zinc, alfalfa, jujube seeds, and much more, so there are no chemicals at all.

No matter whether you are 20 or 60, you can use this supplement to overcome oral issues and get the confidence back that you are missing due to bad odor and sensitive teeth.

Steel Bite Pro Review: Overview of the Supplement

Steel Bite Pro is an all-natural supplement that contains a mix of natural supplements to rebuild your gums and teeth.

The supplement contains 29 different foods that help you reduce the gum pain and other dental problems you have been facing for years.

More than 55,000 people have used Steel Bite Pro till now, and the results of the supplement are pretty impressive. Furthermore, the supplement is prepared in an FDA-approved facility in the USA.

It is available in the form of pills that you can consume anytime, so using the supplement is incredibly convenient. There are numerous benefits of using the Steel Bite Pro as it solves a plethora of dental problems.

Click here to Get the Best Deal on Steel Bite Pro from the Official Website.

Pros and Cons: Steel Bite Pro

To understand the supplement better, it is essential to know about its pros and cons.

Pros

Convenient to Use

The dietary supplement is convenient to use as it comes in the form of pills. You can take the pill anytime, even when you are in your office or somewhere else. Now there is no need to use multiple kinds of toothpaste and splurge money by visiting a dentist.

All-Natural Ingredients

All the ingredients present inside the supplement are natural, and there are no chemicals that can harm your teeth or gums.

Affordable

When you compare the cost of 1 bottle with the cost of a special toothpaste with the fee that your dentist charges, Steel Bite Pro will seem much more affordable. The supplement is available in multiple packages, so you will find it affordable to use.

No Side Effects at All

There are no side effects to using Steel Bite Pro, so you can rest assured that you won't face any headaches or other issues while curing the oral issues. The reason why Steel Bite Pro has no side effects is due to its natural ingredients.

Designed by Experts

The supplement is designed by experts that have been in the industry for years.

No Additional Medicines Are Required

When you are using Steel Bite Pro, you can avoid using other medicines that you have been taking to cure oral issues.

Attacks on the Pain

There are several ingredients present in Steel Bite Pro that attack tooth and gum pain so that you get some instant relief with the supplement.

Comes With a Money Back Guarantee

The supplement comes with a 60-day money back guarantee, so you can claim a full refund if you find the supplement isn't working for you, or if it isn't doing what the manufacturer has promised.

Cons

You Can Purchase It From the Official Site Only

The supplement is only available for purchase from the Official Website. Sometimes the supplement gets out of stock, so you have to wait for it to get back in stock.

A Single Bottle Costs More

If you buy a single bottle of the supplement, it'll cost you more than other packages with multiple bottles.

Ingredients in Steel Bite Pro

All the ingredients present in Steel Bite Pro are natural and have proven benefits for humans. Here is a list of supplements explained in detail and how they can benefit you if you start using Steel Bite Pro.

Turmeric

As per a study, there are innumerable benefits of using turmeric on your teeth. The natural herb has antimicrobial properties that help remove the plaque effectively from the teeth, exterminate bacteria and help cure sensitivity.

Moreover, turmeric is good for fighting oral inflammation issues. When applied on teeth, the ingredient gives instant relief from pain and is effective in curing mouth ulcers as well.

Berberine

Berberine is a natural herb with proven antioxidant power to help you get rid of microorganisms developing inside the mouth. Furthermore, the ingredient has anti-inflammatory properties and is good for curing oral issues caused due to viruses and bacteria.

Yarrow

It is another natural ingredient that is used in a range of health supplements due to its healing power. The ingredient naturally heals the gums and the damage caused to the teeth by bacteria and microorganisms.

As per a study, it helps reduce the infection, oral pain, and cures other dental issues.

Milk Thistle

Your liver has a significant impact on your oral health, and that's where milk thistle works. The natural ingredient eliminates toxins from the liver and detoxifies your mouth as well.

Here is a study that proves how milk thistle is beneficial in detoxifying the liver.

Alfalfa

The decaying of teeth is the initial phase of damage caused by bacteria thriving inside your mouth. Alfalfa works by reducing tooth sensitivity drastically and repairs the tooth decay caused by the bacteria.

It even stops the bacteria from growing further so you can expect good oral health.

Ginger

A lot of natural supplements for teeth contain ginger because of its benefits on the teeth and the stomach. This ingredient present in the Steel Bite Pro reduces nausea and inflammation.

As per this study, there are umpteen other benefits of ginger as well, such as it maintains the pH inside your mouth.

Jujube Seeds

Jujube seeds are good for boosting the immunity. Also, the ingredient has excellent antioxidant properties and is rich in Vitamin C, which is beneficial for the teeth and overall oral health.

Dandelion

Dandelion is a natural ingredient extracted from herbs. The ingredient is rich in minerals and has immense benefits such as fighting the bacteria and preventing the infections occurring inside your mouth.

Zinc

Zinc is essential for teeth, and that is why many toothpaste brands advertise that their product contains a good amount of zinc. Further, zinc is a natural immunity booster and fights against bacteria to prevent gum disease and cavities.

Moreover, zinc repairs the enamel on your teeth that's damaged due to toothpaste or any other reasons. Here is a study that shows the benefits of zinc for your teeth and mouth.

Chicory Root

Chicory root acts as a catalyst and increases the effectiveness of other ingredients. The reason why you get instant relief from pain after using Steel Bite Pro is due to the presence of chicory root in the pills.

Celery Seeds

Bacteria result in bad odor and can create cavities in the teeth. Furthermore, some bacteria result in tooth decay and harm the gums. The celery seeds fight these bacteria and prevent further growth.

Yellow Dock

To stay healthy, the teeth need to absorb the minerals present in the saliva. When your teeth are damaged for any reason, they stop absorbing the minerals, and the damage continues further.

Yellow dock helps the teeth to absorb the minerals while reducing the inflammation. Various studies have proven the efficacy of yellow dock for teeth and gums, and it is a natural and effective ingredient to keep the teeth healthy.

Raspberry, Chanca Piedra, and Artichoke

These three natural ingredients have similar properties and contribute a lot to the effectiveness of Steel Bite Pro. The ingredients have good amounts of vitamins and minerals, including Vitamin K, Vitamin C, magnesium, phosphorus, and folate.

The purifying agents will remove bacteria and other impurities from the mouth so that the other ingredients work well by repairing the teeth and gums.

Feverfew

The worst thing about oral issues is the pain that you have to go through. Steel Bite Pro claims to help with the pain as it contains feverfew, which is a natural pain reliever. The ingredient suppresses oral and dental pain so you will feel better instantly.

As per a study, there are some other benefits of feverfew, because it is a medicinal plant that suppresses other pains as well. Also, there are no side effects of feverfew at all.

Burdock Root

The root of the burdock plant comes loaded with antioxidants that improve the gum health and the overall health of your mouth.

The best thing about Steel Bite Pro is that the ingredients are present in exact quantities, so you can rest assured that there will be no side effects. Every ingredient is tested in the labs for its efficiency, and that's what makes the Steel Bite Pro a considerable option if you want to improve your oral and dental health.

Click here to See the full list of ingredients in Steel Bite Pro on the official website.

How Does Steel Bite Pro Work?

It is crucial to understand how the supplement works so that you can decide whether to invest in it or not. Below is a step by step process that will help you understand Steel Bite Pro on the go.

Step 1:

When you start consuming the supplement, the pills break down in your mouth. The ingredients then mix with saliva to perform their particular actions.

Step 2:

The ingredients fight the bacteria and heal issues such as wounds while reducing the inflammation caused in the mouth.

Step 3:

The supplement cements the root of the teeth so that there are no further oral and dental issues. Also, it heals the gums and repairs the enamel to provide you relief from sensitivity.

The minerals present in these ingredients strengthen the crown area of the teeth while repairing the cracks so that the damage can be stopped.

Step 4:

The supplement also has some impact on your overall health as the ingredients detoxify the liver by flushing away the toxins.

Step 5:

Consuming the supplement regularly will help you maintain the shield on the teeth that fights against bacteria and microorganisms. Also, it improves the condition of the teeth and curtails bad breath.

The working of Steel Bite Pro is really simple, as there are no complex ingredients present in the supplement. It is easy to use, and all you have to do is consume the pill regularly to keep your oral and dental health up to the mark.

Benefits of Steel Bite Pro

There are many benefits of using Steel Bite Pro since it is an all-natural supplement that has no side effects at all. Here are some benefits you need to consider before buying it.

Prevents Bleeding and Improves Gum Health

The reason why your teeth bleed is due to the loose gums. The space between the tooth and the gum results in bleeding, and that's where Steel Bite Pro helps. The supplement tightens the gums so that there is no bleeding at all.

Whitens the Teeth Naturally

The ingredients present in the supplement, such as zinc and milk thistle, whiten the teeth naturally. There is no need to invest in expensive teeth whitening toothpaste if you are using Steel Bite Pro.

Reduces Bad Breath

The supplement contains ingredients that improve the overall health of the teeth, and it automatically reduces bad breath.

Helps Cure Tooth Pain

Steel Bite Pro has feverfew, which is a natural pain reliever ingredient. The ingredient cures tooth and gum pain and can have instant results after you consume Steel Bite Pro.

Click here to Learn more about the Benefits of Steel Bite Pro on the official website.

Side Effects of Using Steel Bite Pro

You may find it surprising, but Steel Bite Pro has no side effects at all as the supplement contains natural ingredients and has exact quantities so that there are no ill effects on your health. If you keep using the supplement as prescribed, then it can have some excellent results.

Who Should Refrain from Steel Bite Pro?

Steel Bite Pro is an all-natural dietary supplement to improve your dental and oral health.

Anyone can use the supplement, including pregnant women and breastfeeding mothers. There are no harms of using the supplement.

However, it would be great to consult a doctor before using the supplement to find out if you are allergic to any of the ingredients.

Dosage and Tips to Start

To get the most from Steel Bite Pro, you should consume two pills with water every day. Take both capsules together anytime that's convenient for you.

To get the best results, follow a brushing regime, and massage your teeth regularly with some good-quality oil to increase the effectiveness of the pills.

Where to Buy Steel Bite Pro, and Guarantees?

You can only buy Steel Bite Pro from the Official Site, as the supplement is not available anywhere else for purchase. You can choose from three available options:

●1 bottle (60 pills) $69

●Three bottles (180 pills) $117

●Six bottles (360 pills) $294 (Best Deal)

You get a 60-day money back guarantee with all the packages, no matter if you go for one bottle or six bottles. You are eligible to claim the full refund within 60 days of the date of purchase.

Steel Bite Pro Reviews: Closing Thoughts

After this definitive review, it will be easier for you to find out whether you should use Steel Bite Pro or not. The supplement contains a mix of 29 natural ingredients that have proven benefits and are tested in labs.

It is essential to get rid of oral and dental issues before things get out of control and you have no option left despite visiting a dentist.

Getting a good quality supplement is essential, so Steel Bite Pro is a viable option if you need a supplement with no side effects.

Anyone can use this supplement irrespective of age, sex, and medical conditions. Lastly, buy the supplement only from the official site so that you can easily claim the refund if required.

Click here to Get the best deal on Steel Bite Pro from the official website.

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A ghost forest in Nags Head Woods, North Carolina on Oct. 16, 2017. NC Wetlands / CC BY 2.0


Along the Atlantic coast, ghost forests provide haunting signs of sea-level rise. These stands of bleached and broken tree trunks are all that remain after salty water inundates a forest.


Matt Kirwan is with the Virginia Institute of Marine Science. He says ghost forests are not a new phenomenon, but they're moving inland faster as seas rise.

"Eventually they'll fall apart and become stumps surrounded by marshland," he says. "And so when you see a ghost forest now, you're seeing where the marsh will be in the future."

Marshes are valuable ecosystems, so in some ways, that's positive.

"Ghost forests are a surprising indicator of ecological resilience in coastal systems," Kirwan says. "They mark how marshes naturally migrate in response to sea-level rise."

But that migration comes at a cost.

"Places that people have lived for hundreds of years are becoming too wet and too salty to grow crops on, in some cases," Kirwan says. "And of course, the forest resources are being lost. And in some cases, people are forced to move from their homes as the land becomes too flooded."

So ghost forests have become eerie symbols of rapid change.

Reposted with permission from Yale Climate Connections.

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