U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Congressionally Requested
Information on EPA
Utilization of Integrated
Risk Information System
Report No. 13-P-0127
January 31, 2013
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Contributors:
Leon Carter
Dwayne Crawford
Christine El-Zoghbi
Elizabeth Grossman
Eric Lewis
Ryan Patterson
Abbreviations
ATSDR Agency for Toxic Substances and Disease Registry
CAA Clean Air Act (Title V Clean Air Act permits)
EPA U.S. Environmental Protection Agency
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
HEAST Health Effects Assessment Summary Tables
IRIS Integrated Risk Information System
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NPDES National Pollutant Discharge Elimination System
NPDWR National Primary Drinking Water Regulations
NSPS New Source Performance Standards
OA Office of the Administrator
OAR Office of Air and Radiation
OCSPP Office of Chemical Safety and Pollution Prevention
OECA Office of Enforcement and Compliance Assurance
OEI Office of Environmental Information
OIG Office of Inspector General
ORD Office of Research and Development
OSWER Office of Solid Waste and Emergency Response
OW Office of Water
PPRTV Provisional-Peer Reviewed Toxicity Values
RCRA-CE Resource Conservation and Recovery Act Criminal Enforcement
RCRA-HWS Resource Conservation and Recovery Act Hazardous Waste Site Restoration
SF Characterization Superfund site characterization
SF-Remedial Superfund site remedial activities
SF-Removal Superfund site removal activities
TSCA Toxic Substances Control Act
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail: OIG Hotline@epa.gov write: EPA Inspector General Hotline
phone: 1-888-546-8740 1200 Pennsylvania Avenue, NW
fax: 202-566-2599 Mailcode 2431T
online: http://www.epa.gov/oiq/hotline.htm Washington, DC 20460
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x^ed sta^
* - U.S. Environmental Protection Agency 13-P-0127
§ \ Office of Inspector General January31 2013
s
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At a Glance
Why We Did This Review
We collected this information in
response to a congressional
request to "determine if EPA
[U.S. Environmental Protection
Agency] program offices and
regions incorporate in their
regulatory decision-making the
exposure dose concentrations
or values that are listed in the
IRIS [Integrated Risk
Information System] database."
IRIS is an EPA Web-based
program that evaluates risk
information on human health
effects that may result from
exposure to environmental
contaminants. IRIS consists of
chemical assessments and
quantitative toxicity values that
have been developed by EPA
and undergone peer review.
IRIS contains information for
more than 550 chemical
substances, including cancer
and non-cancer human health
effects.
This work product addresses
the following EPA Goal or
Cross-Cutting Strategy:
• Advancing science,
research, and technological
innovation
Congressionally Requested Information on EPA
Utilization of Integrated Risk Information System
What We Found
Based on the results of our survey, 85 percent of the EPA survey respondents
reported that they have used IRIS as their primary source for cancer values and
81 percent have used IRIS as their primary source for non-cancer values. More
than half (51 percent) of the survey respondents who reported using IRIS as the
primary source for cancer values indicated a reason they did so was because it
was required for the activity they were conducting. Similarly, more than half
(52 percent) of the survey respondents who reported using IRIS as the primary
source for non-cancer values indicated a reason they did so was because it was
required for the activity they were conducting. About one-third (34 percent) of the
survey respondents reported that they have used an alternate source for toxicity
values when an IRIS value was available. The primary reason selected for using
an alternate source was that the alternate source was more up-to-date with
current scientific practice or information.
We found no EPA policy mandating the use of any toxicity database including
IRIS. The Office of Solid Waste and Emergency Response has issued a directive
that recommends using EPA's IRIS as the first tier source of human health
toxicity values. Sixty-seven percent of the respondents to this survey reported
that they have used IRIS for Superfund program activities. Sixty-five percent of
respondents also indicated that there are standard operating procedures
regarding how to choose a source of toxicity values. Sixteen percent of
respondents identified the Office of Solid Waste and Emergency Response
directive as this standard operating procedure.
All survey responses were self-reported by the EPA respondents and were not
verified by the Office of Inspector General.
We make no recommendations in this work product.
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2013/
20130131-13-P-0127.pdf
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
January 31, 2013
MEMORANDUM
SUBJECT: Congressionally Requested Information on EPA Utilization of
Integrated Risk Information System
Report No. 13-P-0127
FROM: Arthur A. Elkins, Jr.
TO:
Lek Kadeli
Acting Assistant Administrator for Research and Development
This is our final work product on the results of a survey of U.S. Environmental Protection
Agency (EPA) staff conducted by the Office of Inspector General (OIG). We designed and
conducted the survey and analyzed results from April 2012 through January 2013 in response to
a congressional request. The purpose of the survey was to assess the EPA's use of the Integrated
Risk Information System (IRIS).
Because this work product contains no recommendations, you are not required to respond to this
document. Therefore, this work product is considered closed.
We have no objections to the further release of this report to the public. We will post this report to
our website at http://www.epa.gov/oig.
Should you have any questions, please contact Carolyn Copper, Assistant Inspector General for
Program Evaluation, at (202) 566-0829 or copper.carolyn@epa.gov; or Eric Lewis, Director,
Special Reviews, at (202) 566-2664 or lewis.eric@epa.gov.
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Congressionally Requested Information on
EPA Utilization of Integrated Risk Information System
13-P-0127
Table of C
Chapters
1 Introduction 1
Purpose 1
Background 1
Scope and Methodology 2
2 Results of Survey 3
Why some respondents use IRIS 4
Why some respondents use an alternate source 6
Why some respondents or their teams use alternate values
for substances available in IRIS 8
Respondents developing their own toxicity values 10
Remaining responses to the OIG IRIS Utilization Survey 11
Status of Recommendations and Potential Monetary Benefits 19
Appendices
A Survey
B Distribution
20
26
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Chapter 1
Introduction
Purpose
In February 2012, the Office of Inspector General (OIG), U.S. Environmental
Protection Agency (EPA), received a congressional request to "determine if EPA
program offices and regions incorporate in their regulatory decision-making the
exposure dose concentrations or values that are listed in the IRIS [Integrated Risk
Information System] database." In response, we sought to determine:
1) Which EPA offices and regions utilize data derived from IRIS assessments
or other similar systems.
2) How EPA offices and regions utilize data derived from IRIS assessments.
3) The circumstances under which EPA offices and regions use IRIS or an
alternate system.
Background
IRIS is a human health assessment program that evaluates risk information on
effects that may result from exposure to environmental contaminants. The IRIS
program includes a Web-based database of chemical assessments and quantitative
toxicity values that have been developed by EPA and undergone peer review. The
IRIS database contains information for more than 550 chemical substances,
including cancer and non-cancer human health effects that may result from
exposure to various substances in the environment.
The National Center for Environmental Assessment within the Office of Research
and Development (ORD) prepares the IRIS assessments, manages the peer review
process, and maintains the online database. According to the National Center for
Environmental Assessment, the main purpose of IRIS is to meet EPA statutory,
regulatory, or program implementation needs with special emphasis on chemicals
of high interest to the public or other levels of government.
IRIS is not the only source available to EPA employees for toxicity values. Other
toxicity databases available to EPA staff include, but are not limited to:
• Provisional-Peer Reviewed Toxicity Values (PPRTVs), ORD Office of
Superfund Remediation and Technology Innovation, EPA.
• Health Effects Assessment Summary Tables (HEAST), ORD Office of
Superfund Remediation and Technology Innovation, EPA.
• California Environmental Protection Agency toxicity database.
• Agency for Toxic Substances and Disease Registry's (ASTDR's) Minimal
Risk Levels.
13-P-0127
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We found no EPA policy mandating the use of any toxicity database, including IRIS.
OSWER has issued a directive that identifies IRIS as the first tier of a hierarchy of
databases and as the generally preferred source of human health toxicity values. The
second tier is EPA's PPRTVs; the third tier includes other sources of information.
Scope and Methodology
We conducted this review from April 2012 to January 2013 and completed the
survey from April to June 2012. We completed this review in accordance with
generally accepted government auditing standards, except that we did not verify
the information reported by survey respondents and did not use statistical
techniques for selecting the survey participants. These efforts would likely have
delayed reporting significantly. Not complying with these two elements of the
standards does not have an effect on the outcome of this review. The scope of
work completed sufficiently addresses the purpose of this review.
We designed a survey with 23 questions addressing the Agency's use of IRIS.
The survey responses were self-reported by EPA personnel and were not verified
by the OIG. A copy of the survey questions are in appendix A.
The survey included four opportunities for respondents to provide write-in
answers. These write-in answers contain some information that is personally
identifiable to specific respondents and did not provide quantifiable responses for
analysis. The responses therefore are not included in this work product.
Participant Selection
All survey participants were current EPA employees at that time. We selected
survey participants from two sources:
1. We contacted Agency audit follow-up coordinators from all 10 regional
and 12 program offices and asked them to identify "EPA
managers/supervisors/team leaders who work with, or supervise teams
who work with, toxicity values provided in IRIS or other similar systems."
We did not include OIG in our survey. This list identified 67 individuals.
2. We also used names provided by ORD. This list contained managers and
senior scientists who use human health toxicity values in their groups.
This list identified 442 individuals.
ORD also provided us with a second contact list. However, these individuals were
not included in the survey due to the methodology used to select these individuals.
After collating the lists and eliminating redundancies, we invited 415 individuals
to participate in the survey. The response rate was 93 percent (387 respondents).
However, after adjustments for partial responses (11), unconfirmed EPA
employment status (2), and the non-use of carcinogenic or non-carcinogenic
toxicity values (74), we had 300 responses from EPA personnel who stated that
they used toxicity values in their work.
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Chapter 2
Results of Survey
Of the 300 survey respondents, 256 (85 percent) indicated that IRIS was their
primary source for carcinogenic toxicity values, and 242 (81 percent) indicated
that IRIS was their primary source for non-cancer toxicity values. This chapter
summarizes why respondents primarily use IRIS or an alternate source, why
respondents use alternate values when a substance is available in IRIS, and how
many respondents developed their own toxicity values. We also noted the
following:
• Although 85 percent of the respondents indicated that they use IRIS as
their primary source to provide carcinogenic toxicity values, less than
30 percent of the respondents identified a reason they use IRIS as either
scientific accuracy, the ability to verify the data, or the currency of data.
• Thirty-four percent of all respondents (103) indicated that they have
experienced a situation in which they researched a substance that was
listed in IRIS but used toxicity values from another source instead. The
majority of respondents (68 percent) who indicated that they used an
alternate value from a source other than IRIS for substances available in
IRIS cited currency with scientific practice or information as a reason they
chose an alternate value.
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Why some respondents use IRIS
Survey question 10 allowed the respondents to select up to three possible reasons
why IRIS is used as the primary source for carcinogenic toxicity values. Because
each respondent could select up to three responses, the sum of percentages for all
answers is greater than 100 percent. As shown in figure 1, the percentage of
respondents selecting each response is:
Data in IRIS is more scientifically accurate than other sources (selected by
29% of respondents).
The IRIS approach is more up to date with current scientific practice or
information than other sources (selected by 21% of respondents).
IRIS is more accessible than other sources (selected by 16% of
respondents).
Data in IRIS is more applicable to my specific work environment than
other sources (selected by 41% of respondents).
The validity of the IRIS data is easier to verify than other sources (selected
by 27% of respondents).
Use of IRIS is required for the activity I and/or my team are completing
(selected by 51% of respondents).
Figure 1: Reasons why IRIS is the primary source for carcinogenic toxicity values
N=256
50
29
21
¦
16
¦
I
27
1
Data in IRIS is more IMS approach is more up-
scicntitically accurate than to date with current
other sources. scientific practice or
information than other
sources.
IUIS is more accessible
than other sources.
Data in litis is more Validity of data in lltlS is Use of IRIS is required for
applicable to my specific easier to verify than other the activity I and/or my
work environment than sources. team are completing,
other sources.
Answer Options
Note: N represents the number of respondents who answered this question. Percentages were rounded to the
nearest whole number.
Source: OIG's IRIS utilization survey results.
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Survey question 15 allowed the respondents to select up to three possible reasons
why IRIS is used as the primary source for non-cancerous toxicity values.
Because each respondent could select up to three responses, the sum of
percentages for all answers is greater than 100 percent. As shown in Figure 2, the
percentage of respondents selecting each response is:
• Data in IRIS is more scientifically accurate than other sources (selected by
31% of respondents).
• The IRIS approach is more up to date with current scientific practice or
information than other sources (selected by 22% of respondents).
• IRIS is more accessible than other sources (selected by 19% of
respondents)
• Data in IRIS is more applicable to my specific work environment than
other sources (selected by 41% of respondents).
• The validity of the IRIS data is easier to verify than other sources (selected
by 24% of respondents)
• Use of IRIS is required for the activity I and/or my team are completing
(selected by 52% of respondents).
Figure 2: Reasons why IRIS is the primary source for non-cancerous toxicity values
N=242
bU
!>2
§
S 41
i. 40 ^
j i i ¦ I i I
Data in iKli is more IRIS approach is more up- Rli> is more accessible Data in ikis s more validity of data in IKIS is use of irii> isrequirec for
scientifically acorate than to-date with curreit th3n other sou-ces. applicableto my specific easier tc venfy tian other the activity l anc/or my
other wiurr.es. srientificpraclice or work environment than sources. team are completing,
inform?.heir than other other sources.
. ,, sources.
¦ Question lb
Answer Options
Note: N represents the number of respondents who answered this question. Percentages were rounded to the
nearest whole number.
Source: OIG's IRIS utilization survey results.
13-P-0127
5
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Why some respondents use an alternate source
Only 8 percent of respondents reported that in conducting their main activity they
did not use IRIS for either carcinogenic or non-cancerous toxicity values. We
sought to understand through a series of questions what alternate source they use
and why they use an alternate source.
Of the 300 respondents, 44 (15 percent) indicated that IRIS is not their primary
source for carcinogenic toxicity values.
Survey question 11 allowed the respondents to select up to three possible reasons
why they use an alternate source for carcinogenic toxicity values. Because each
respondent could select up to three responses, the sum of percentages for all
answers is greater than 100 percent. As shown in figure 3, the percentage of
respondents selecting each response is:
• Data in alternate source is more scientifically accurate (selected by 11% of
respondents).
• Alternate source is more up-to-date with current scientific practice or
information (selected by 20% of respondents).
• Alternate source is more accessible (selected by 32% of respondents).
• Data in alternate source is more applicable to my specific work
environment (selected by 52% of respondents).
• Validity of data in alternate source is easier to verify (selected by 5% of
respondents).
• The state (in which activity is undertaken) requires an alternative source
(selected by 9% of respondents).
• Substance researched is not available in IRIS (selected by 27% of
respondents).
Figure 3: Reasons why respondents use an alternate source for carcinogenic toxicity values
N=44
0
Data in alternate Alternate source Alternate source s
smirrp iv mnrp apprrarh k mnrp up- mnrp arrp
-------
Of the 300 respondents, 58 (19 percent) indicated that IRIS is not their primary
source for non-cancerous toxicity values. Survey question 16 allowed the
respondents to select up to three possible reasons why they use an alternate source
for non-cancerous toxicity values. Because each respondent could select up to
three responses, the sum of percentages for all answers is greater than
100 percent.
• Data in alternate source is more scientifically accurate (selected by 12% of
respondents).
• Alternate source approach is more up-to-date with current scientific
practice or information (selected by 28% of respondents).
• Alternate source is more accessible (selected by 31% of respondents).
• Data in alternate source is more applicable to my specific work
environment (selected by 45% of respondents).
• Validity of data in alternate source is easier to verify (selected by 5% of
respondents).
• The state (in which activity is undertaken) requires an alternative source
(selected by 7% of respondents).
• Substance researched is not available in IRIS (selected by 38% of
respondents).
Figure 4: Reasons why an alternate source is used for non-cancerous toxicity values
N=58
50 4S
I"
H—
=T
Data in alternate Alte'nate source Alternate source is Data in alternate Validity otdata in Alternate source is Substance researched
source is more approach ii more tp- more accessible. source is more alternate source is required by state in is not available in RIS.
scientifically accurate, to date with current applicable to my easier to verify. which activity is
scientific practice or specific work undertaken,
information. environment.
¦QualiwilS
Note: N represents the number of respondents who answered this question. Percentages were rounded to the
nearest whole number.
Source: OIG's IRIS utilization survey results.
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Why some respondents or their teams use alternate values for
substances available in IRIS
Of the 300 respondents, 103 (34 percent) indicated that they have experienced a
situation in which they or their team researched a substance listed in IRIS but
used a toxicity value from another source instead of those available in IRIS.
Figure 5 shows the number of respondents in each office who reported that they
had experienced such a situation.
Figure 5: Respondents who use alternate values for substances available in IRIS (by office
N=300
CT
QJ
b ^
\Cp sfP ^ sCf* K
^ ^ ^ ^ ^ ^ 4$
Yes
Program Office/Region
Note: Abbreviations for program offices identified are listed in the below paragraph (OEI stands for Office of
Environmental Information). A total of 300 respondents answered the question. This figure displays only the
103 respondents that answered the question in the affirmative.
Source: OIG's IRIS utilization survey results.
While 34 percent of all respondents indicated experiencing a situation in which
they researched a substance listed in IRIS but used a toxicity value from another
source instead, more than 30 percent of the respondents from the following
offices indicated they had experienced this situation:
• Office of the Administrator (OA)
• Office of Air and Radiation (OAR)
• Office of Chemical Safety and Pollution Prevention (OCSPP)
• Office of Enforcement and Compliance Assurance (OECA)
• Office of Research and Development (ORD)
• Office of Solid Waste and Emergency Response (OSWER)
• Office of Water (OW)
• Regions 9 and 101
1 OA, OECA, ORD, and OWhad fewer than 10 survey respondents; further details are in Figure 8.
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Survey question 19 allowed the respondents to select up to three possible reasons
why they use alternate values for substances that are available in IRIS. Because
each respondent could select up to three responses, the sum of percentages for all
answers is greater than 100 percent. As shown in Figure 6, the percentage of
respondents selecting each response is:
• Data in alternate source is more scientifically accurate (selected by 20% of
respondents).
• Alternate system source is more up-to-date with current scientific practice
or information (selected by 68% of respondents).
• Alternate source is more accessible (selected by 5% of respondents).
• Data in alternate source is more applicable to my specific work
environment (selected by 43% of respondents).
• Validity of data in alternate source is easier to verify (selected by 3% of
respondents).
• The state (in which activity is undertaken) requires an alternative source
(selected by 22% of respondents).
Figure 6: Reasons why respondents use alternative values for substances available in IRIS
N=103
8'J -|
.
I "M ¦
Data in alternate source is Alternate system source is Alternate sou'ce ismore Data in alternate source Is validity of data in Alternate souro
nore scientifically more up-to-date w th accessible. more applicable to my alternate source is easier required by state in
accurate. current scientific practice specific work environment. to verify. activity is undertc
or information.
_ _ „ Answer Options
¦ Question 19
Note: N represents the number of respondents who answered this question. Percentages were rounded to the
nearest whole number.
Source: OIG's IRIS utilization survey results.
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Respondents developing their own toxicity values
Of the 300 respondents, 85 (28 percent) indicated that they had experienced a
situation in which they or their team developed their own toxicity values. Figure 7
shows the number of respondents in each office who reported having experienced
such a situation.
Figure 7: Respondents developing their own toxicity values (by office)
Program Office/Region
Note: N represents the number of respondents who answered this question. This figure displays only those who
answered the question in the affirmative.
Source: OIG's IRIS utilization survey results.
More than 30 percent of respondents in two program offices (OCSPP and OW)
and three regions (4, 6, and 8), reported having experienced a situation in which
they or their team developed their own toxicity values.
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Remaining responses to the OIG IRIS Utilization Survey
The following graphs (figures 8-21) show the remaining IRIS utilization survey
questions and responses (questions 1-8, 12, 13, 17, 18, 20, and 22) not previously
illustrated in this work product.
Figure 8: Question 1
For which Office/Region do you work?
N=300
45
39
40
36
35
30
26
24
25
20
14
15
10
5
0
# rcf r# # ^ ^ ^ ^ ^ ^ ^
Program Office/Region
Source: OIG's IRIS utilization survey results.
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Figure 9: Question 2
Question 2: Where are you located?
N=300
90
SO
70
60
5*
£ 50
QJ
= 40
£ 30
LL
20
10
0
77
i r
17 19 19
43 — — — tt-
«» A
V nO 0<> (f* nO 00 rjO 00 -° °
V
Location
Source: OIG's IRIS utilization survey results.
Figure 10: Question 3
120
100
U 80
c
{LI
D- 60
oj
40
20
0
What is your pay category/grade?
N=300
105
78 76
1
¦
IU
z
GS-7 Lo GS-12 GS-13
GS-14 GS-15 Senior Scientist SES
GS Level/ Pay Category
Source: OIG's IRIS utilization survey results.
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12
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Figure 11: Question 4
What is your supervisory status?
N=300
Supervisor
135
Non-
Supervisor
165
Source: OIG's IRIS utilization survey results.
Figure 12: Question 5
What is the main activity for which you or your team use carcinogenic or non-cancerous toxicity values?
N=300
18
20
1
2
Calculating regional Calculating a chemical's Calculatingthe risk level Evaluating toxicity Setting cleanup Supporting regulatory
screening levels exposure level corresponding to a values in the Five Year levels/calculating develoomentor
corresponding to a given risk level Review screening rulemaking
given chemical levels/calculating
exposure level preliminary remediation
¦ Question 5 Soals
Answer Options
Source: OIG's IRIS utilization survey results.
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Figure 13: Question 6
In the past five years, identify the program activities that you in
your current position or your team have used the toxicity values
from the IRIS database to support. (Please check all that apply.)
¦ Question 6 i
EPA Activities §
Note: Abbreviated program activities identified: National Ambient Air Quality Standards (NAAQS); National Emission
Standards for Hazardous Air Pollutants (NESHAP); New Source Performance Standards (NSPS); Title V Clean Air
Act permits (CAA); National Primary Drinking Water Regulations (NPDWR); National Pollutant Discharge Elimination
System (NPDES); Toxic Substances Control Act (TSCA); Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA); Resource Conservation and Recovery Act Criminal Enforcement (RCRA-CE); Resource Conservation and
Recovery Act Hazardous Waste Site Restoration (RCRA-HWS); Superfund site characterization
(SF-Characterization); Superfund site removal activities (SF-Removal); and Superfund site remedial activities
(SF-Remedial).
Source: OIG's IRIS utilization survey results.
Figure 14: Question 7
In conducting your main activity, do you or your team use
EPA's IRIS carcinogenic toxicity values?
N=300
Source: OIG's IRIS utilization survey results.
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Figure 15: Question 8
In conducting your main activity, what is the primary information source you use to
obtain a chemical's carcinogenic toxicity value?
N=300
10
3 1 1
i i
EPA's IRIS ATSDR HEAST PPRTVs Other
Toxicity databases
Source: OIG's IRIS utilization survey results.
Figure 16: Question 12
In conducting your main activity, do you or your team use EPA's IRIS non-cancerous
toxicity values?
N=300
No
10%
Yes
90%
Source: OIG's IRIS utilization survey results.
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Figure 17: Question 13
In conducting your main activity, what is the primary information source you use to obtain a
chemical's non-cancerous toxicity value?
N=300
90
EPA's IRIS ATSDR HEAST PPRTVs Other
Toxicity Databases
Source: OIG's IRIS utilization survey results.
Figure 18: Question 17
How frequently do you or your team incorporate toxicity values different from those
provided in IRIS into your office's final products
N=300
35 I 32
¦
I l l l
0 -I 1 1 1 1 1 1
Always Frequently Sometimes Rarely Never I don't know
Answer options
Source: OIG's IRIS utilization survey results.
13-P-0127 16
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Figure 19: Question 18
Have you experienced a situation in which you or your team researched a
substance that was listed in IRIS but you used toxicity values from another
source instead of those available in IRIS?
N=300
Yes
34%
No
66%
Source: OIG's IRIS utilization survey results.
Figure 20: Question 20
Have you experienced a situation in which you or your team developed your own toxicity
values?
N=300
Yes
28%
No
72%
Source: OIG's IRIS utilization survey results.
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Figure 21: Question 22
Are there any Standard Operating Procedures or other guidance regarding how to choose
a source of toxicity values for your office's work?
N=300
No
35%
Yes
65%
Source: OIG's IRIS utilization survey results.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
No recommendations
Claimed
Amount
Ag reed-To
Amount
1 0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is unresolved with resolution efforts in progress
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Survey
Appendix A
For which Office/Region do you work?
(3 Region 1
(3 Region 2
(3 Region 3
(3 Region 4
(3 Region 5
(3 Region 6
(3 Region 7
(3 Region 8
(3 Region 9
(3 Region 10
(3 Office of the Administrator (OA)
(3 Office of Administration and Resources Management (OARM)
(3 Office of Air and Radiation (OAR)
(3 Office of the Chief Financial Officer (OCFO)
(3 Office of Chemical Safety and Pollution Prevention (OCSPP)
(3 Office of Enforcement and Compliance Assurance (OECA)
(3 Office of Environmental Information (OEI)
(3 Office of General Counsel (OGC)
(3 Office of Inspector General (OIG)
(3 Office of International and Tribal Affairs (OITA)
(3 Office of Research and Development (ORD)
(3 Office of Solid Waste and Emergency Response (OSWER)
(3 Office of Water (OW)
Where are you located?
(3 Region 1
(3 Region 2
(3 Region 3
(3 Region 4
(3 Region 5
(3 Region 6
(3 Region 7
(3 Region 8
(3 Region 9
(3 Region 10
(3 Headquarters
(3 Research Triangle Park
(3 Cincinnati
(3 Other, please specify below.
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What is your pay category/grade?
O GS-1
(3 GS-2
(3 GS-3
(3 GS-4
(3 GS-5
(3 GS-6
(3 GS-7
(3 GS-8
(3 GS-9
(3 GS-10
(3 GS-11
(3 GS-12
(3 GS-13
(3 GS-14
(3 GS-15
(3 Senior Executive Service
(3 Senior Level or Scientific or Professional
(3 Other
What is your supervisory status?
(3 Non-Supervisor
(3 Supervisor
What is the main activity for which you or your team use carcinogenic or non-cancerous toxicity values?
(3 Setting cleanup levels/calculating screening levels/calculating preliminary remediation goals
(3 Supporting regulatory development or rulemaking
(3 Calculating a chemical's exposure level corresponding to a given chemical exposure level
(3 Calculating the risk level corresponding to a given risk level
(3 Calculating Regional Screening Levels
(3 Evaluating toxicity values in the Five Year Review
(3 I and my team do not use carcinogenic or non-cancerous toxicity values.
In the past five years, identify the program activities that you in your current position or your team have
used the toxicity values from the IRIS database to support. (Please check all that apply.)
National Ambient Air Quality Standards (NAAQS)
National Emission Standards for Hazardous Air Pollutants (NESHAP)
New Source Performance Standards (NSPS)
i , Title V Clean Air Act (CAA) permits
I , National Primary Drinking Water Regulations (NPDWR)
i , National Pollutant Discharge Elimination System (NPDES)
Toxic Substances Control Act (TSCA)
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
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i , Resource Conservation and Recovery Act (RCRA) Criminal Enforcement
Resource Conservation and Recovery Act (RCRA) Hazardous waste site restoration
i , Superfund site characterization
I , Superfund site removal activities
Superfund site remedial activities
Other, please specify below
In conducting your main activity, do you or your team use EPA's IRIS carcinogenic toxicity values?
(3 Yes
O No
In conducting your main activity, what is the primary information source you use to obtain a chemical's
carcinogenic toxicity value?
(3 EPA's IRIS [Integrated Risk Information System]
(3 PPRTVs [Provisional Peer-Reviewed Toxicity Values] HEAST [Health Effects Assessment
Summary Tables]
(3 CalEPA [California Environmental Protection Agency] toxicity database
(3 ATSDR [Agency for Toxic Substances and Disease Registry] Minimal Risk Levels
(3 Other
Please identify the primary information source you use to obtain a chemical's carcinogenic toxicity value.
You indicated that IRIS is the primary source you use to obtain a chemical's carcinogenic toxicity value.
Why is IRIS your primary source? You may choose up to three (3) responses.
Data in IRIS is more scientifically accurate than other sources.
IRIS approach is more up-to-date with current scientific practice or information than other
sources.
IRIS is more accessible than other sources.
i , Data in IRIS is more applicable to my specific work environment than other sources.
I , Validity of data in IRIS is easier to verify than other sources,
i , Use of IRIS is required for the activity I and/or my team are completing.
You indicated IRIS is not the primary source of carcinogenic toxicity values for your main activity. Why do
you use an alternate source (which contains values different than IRIS) instead of IRIS? You may choose
up to three (3) responses.
Data in alternate source is more scientifically accurate.
Alternate source approach is more up-to-date with current scientific practice or information,
i , Alternate source is more accessible.
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i , Data in alternate source is more applicable to my specific work environment.
Validity of data in alternate source is easier to verify,
i , Alternate source is required by state in which activity is undertaken.
I , Substance researched is not available in IRIS.
In conducting your main activity, do you or your team use EPA's IRIS non-cancerous toxicity values?
(3 Yes
O No
In conducting your main activity, what is the primary information source you use to obtain a chemical's
non-cancerous toxicity value?
(3 EPA's IRIS [Integrated Risk Information System] PPRTVs [Provisional Peer-Reviewed
Toxicity Values]
(3 HEAST [Health Effects Assessment Summary Tables]
(3 CalEPA [California Environmental Protection Agency] toxicity database
(3 ATSDR [Agency for Toxic Substances and Disease Registry] Minimal Risk Levels
Please identify the primary information source you use to obtain a chemical's non-cancerous toxicity
value.
You indicated that IRIS is the primary source you use to obtain a chemical's non-cancerous toxicity value.
Why is IRIS your primary source? You may choose up to three (3) responses.
Data in IRIS is more scientifically accurate than other sources
IRIS approach is more up-to-date with current scientific practice or information than other
sources.
IRIS is more accessible than other sources.
Data in IRIS is more applicable to my specific work environment than other sources.
I , Validity of data in IRIS is easier to verify than other sources,
i , Use of IRIS is required for the activity I and/or my team are completing.
You indicated IRIS is not the primary source of non-cancerous toxicity values for your main activity. Why
do you use an alternate source (which contains values different than IRIS) instead of IRIS? You may
choose up to three (3) responses.
Data in alternate source is more scientifically accurate.
Alternate source approach is more up-to-date with current scientific practice or information,
i , Alternate source is more accessible.
I , Data in alternate source is more applicable to my specific work environment,
i , Validity of data in alternate source is easier to verify.
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i , Alternate source is required by state in which activity is undertaken.
Substance researched is not available in IRIS.
How frequently do you or your team incorporate toxicity values different from those provided in IRIS into
your office's final products?
(3 Always
(3 Frequently
(3 Sometimes
(3 Rarely
(3 Never
(3 I don't know
Have you experienced a situation in which you or your team researched a substance that was listed in
IRIS but you used toxicity values from another source instead of those available in IRIS?
(3 Yes
(3 No
You indicated that you have experienced a situation in which you or your team researched a substance
that was listed in IRIS but you used toxicity values from another source. In that situation, why did you use
the values from the other source? You may choose up to three (3) responses.
Data in alternate source is more scientifically accurate.
Alternate system source is more up-to-date with current scientific practice or information.
Alternate source is more accessible.
Data in alternate source is more applicable to my specific work environment.
I , Validity of data in alternate source is easier to verify,
i , Alternate source is required by state in which activity is undertaken.
Have you experienced a situation in which you or your team developed your own toxicity values?
(3 Yes
(3 No
Please describe the situation in which you or your team developed your own toxicity values.
Are there any Standard Operating Procedures or other guidance regarding how to choose a source of
toxicity values for your office's work?
(3 Yes
(3 No
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Please provide further information regarding your Standard Operating Procedures for choosing a source
of toxicity values such as guidance title, URL, or other identifying information. If you have no further
information, please enter "None." Please email a PDF of the guidance you use (if available) to ... [Email
address of OIG employee included here in actual survey]
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Research and Development
Deputy Assistant Administrator for Science, Office of Research and Development
Principal Deputy Assistant Administrator for Management, Office of Research and Development
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Director, National Center for Environmental Assessment, Office of Research and Development
Deputy Director, National Center for Environmental Assessment, Office of Research and
Development
Associate Director for Health, National Center for Environmental Assessment, Office of
Research and Development
Associate Director for Ecology, National Center for Environmental Assessment, Office of
Research and Development
Audit Follow-Up Coordinator, Office of Research and Development
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