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Illinois Attorney General Kwame Raoul
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June 2, 2020


Chicago — Attorney General Kwame Raoul today joined a coalition of 14 attorneys general in submitting comments criticizing the Environmental Protection Agency’s finding that certain uses of asbestos present no unreasonable risk to human health.

In the comment letter, Raoul and the coalition argue that the EPA’s draft risk evaluation for asbestos violates the Toxic Substances Control Act (TSCA) and Congress’ intent that the EPA consider all uses of asbestos in its evaluation. The coalition also notes that the findings in the evaluation are is unsupported by the EPA’s own assessment and urges the agency to obtain the information needed to conduct the necessary, thorough evaluations of the risks presented by asbestos.

“Asbestos is a dangerous carcinogen, and exposure has been connected to serious and life-threatening medical conditions,” Raoul said. “The EPA’s most recent findings are based on incomplete information, and I am urging the agency to conduct a thorough evaluation of the dangers posed by exposure to asbestos.”

Asbestos – a carcinogen that takes 15,000 lives per year – is linked to diseases that are life-threatening or cause substantial pain and suffering, including mesothelioma, fibrosis, lung cancer, gastrointestinal cancer, and other lung disorders and diseases. There is no safe level of exposure to this highly toxic material, and addressing its risks were among Congress’ priorities in reforming the TSCA.

On April 3, the EPA released its preliminary conclusions, findings and determinations in its draft risk evaluation of asbestos. This evaluation relies on an incomplete and inadequate characterizations of the use of asbestos and finds that the conditions of use of asbestos — including importation of asbestos and asbestos-containing products — present no unreasonable risk to human health and the environment. In addition, in the draft risk evaluation, the EPA continues to exclude exposures to legacy asbestos from its risk evaluation, even though the vast majority of asbestos in the U.S. exists as legacy material. Legacy material is asbestos that is currently in place in buildings and on pipes and equipment, vehicles, underground and elsewhere.

In the comment letter, Raoul and the coalition argues that the EPA’s draft risk evaluation is fatally-flawed and contradicts the TSCA and Congress’ intent. The coalition highlights that the EPA:

  • Concedes that the use of commercial and consumer asbestos identified in the draft risk evaluation presents an unreasonable cancer risk.
  • Admits in the draft risk evaluation that it lacks sufficient information to be able to evaluate risks to people from imported articles containing asbestos.
  • Violates the TSCA when it claims to find no unreasonable risk presented by articles containing asbestos.

Joining Raoul in filing the comment letter are the attorneys general of California, the District of Columbia, Hawaii, Maine, Maryland, Massachusetts, Minnesota, New Jersey, New York, Oregon, Rhode Island, Vermont and Washington.


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