Comments on EPA’s Draft Risk Evaluation of Asbestos

Paustenbach and Associates (2020)



In March 2020, EPA published a Draft Risk Evaluation for Asbestos (Docket EPA-HQ-OPPT-2019-0501) in which they reviewed a suite of potential exposure scenarios for workers, occupational non-users, consumers, and bystanders potentially exposed to chrysotile. The focus of the EPA efforts was to evaluate current and future risks regarding working with asbestos containing products in the coming years.


In its review, EPA made the following initial determinations regarding the alleged risks:


1. No risk to the environment. For all the conditions of use included in the draft risk evaluation, EPA preliminarily found no unreasonable risks to the environment under any conditions of use.


2. An unreasonable risk to workers, occupational non-users, consumers, and bystanders. EPA indicated that they believed that future exposures to chrysotile contained in gaskets, vehicle brakes, and oil rig brakes are a significant public health hazard.



Our Work


The team at Paustenbach and Associates submitted a 136 page set of comments to the EPA on May 26, 2020. In the executive summary provided below, we described the 33 significant shortcomings in the EPA’s analysis and approach towards characterizing the alleged hazards that chrysotile poses at present and in the future to workers, occupational non-users, consumers, and bystanders.


For a detailed discussion of these shortcomings, we have posted the full comments below.   


Executive Summary


Full Version