OEHS and EPA: Collaborating on Chemical Risk Evaluations
By Abby Roberts
June 9, 2026—The implementation of the Toxic Substances Control Act has been a major source of tension between EPA and industry OEHS professionals in recent years. In an educational session given June 2 at AIHA Connect 2026, Paul DeLeo, PhD, described how much of this tension results from different ways of looking at chemicals. While EPA looks at the management of chemicals through every phase of their life cycles, he explained, OSHA and OEHS professionals address chemicals through the lens of occupational health and safety.
The TSCA process moves chemicals through prioritization, risk evaluation, and risk management stages. Co-presenter Silvia Maberti, PhD, FAIHA, explained that EPA’s risk evaluation process is different than what OEHS professionals are used to. For example, EPA considers conditions of use, even though different conditions of use may not be easily separated in practice. EPA also considers occupational scenarios, which may not align with significant exposure groups. It’s also possible for the same condition of use to appear in different exposure scenarios. “It’s fairly convoluted because the process is convoluted,” Maberti said, referring to EPA’s method for relating conditions of use to assessed occupational scenarios.
EPA seeks information for risk evaluations from sources such as industry-submitted monitoring data, peer-reviewed literature, surrogate data, and exposure modeling. Maberti explained that EPA looks mainly at “sentinel scenarios,” or plausible upper-bound exposures, which leads the agency to make conservative risk estimates. But industry OEHS professionals don’t have the context to satisfy EPA’s data requests, she said. As a result, the agency may misalign exposure scenarios with work site activities and over- or under-prescribe controls. She stressed the importance of aligning EPA and OEHS on terminology, approaches, the use of general and site-specific data, and a philosophy of controls.
DeLeo then explained how EPA uses models to estimate exposure. In the absence of evidence, EPA’s risk estimates skew conservative. For example, when estimating a worker’s dermal exposure to a chemical in an adhesive product, EPA may assume that the chemical will totally coat the worker’s hands and that all of it will be absorbed, which may not be realistic in practice. DeLeo urged OEHS professionals to educate EPA staff on how their industries work by providing information about work patterns, activities, the frequency and duration of exposures, and standard exposure mitigation practices.
“EPA is going to be doing assessments for a lot of chemicals,” said Andrew Maier, PhD, CIH, DABT, FAIHA, DeLeo and Maberti’s final co-presenter. “The assessments will only be as good as the information they have.”
According to Maier, EPA is very receptive to receiving data from OEHS professionals, who can play a very important role in the agency’s decision-making. He added that OEHS professionals should annotate any data they submit to EPA, providing context on factors such as worker characteristics, work operations and processes, environmental factors, and sampling methods. This will help ensure EPA’s risk estimates are more representative of real workplace exposures, including when controls are in place.
With EPA planning to focus more on aggregate and cumulative exposures, Maier urged OEHS professionals to become engaged with the entire value chains of their organization’s products. Finally, he invited any OEHS professionals interested in improving EPA’s risk evaluation process to join AIHA’s TSCA Advisory group.
For more information on TSCA, read “Bridging Expertise” and “TSCA in Transition” in The Synergist.
Abby Roberts is an assistant editor for The Synergist.