RDX Evaluation by US EPA - Why It Matters    May 18, 2016


EPA's IRIS program released a draft evaluation of RDX in early 2016 that does not sufficiently address evidence of the cancer hazard and discounts information that should be considered.  RDX is a common contaminant on and around military bases because it was and is used in military weapons.  It currently contaminants soil, air and water. 


Failing to acknowledge and address the compelling cancer evidence seriously undermines federal protections of drinking water and other media.  EPA has categorized RDX so that it will not achieve the status as a carcinogen that would result in it being sufficiently regulated.


This failure was the subject of comments by Dr. Ronald Melnick, a retired NIEHS toxicologist who specializes in cancer-causing chemicals.  His critique of the IRIS approach to RDX was formally submitted to the EPA RDX docket prior to the May public meeting (link:  Comments on IRIS draft RDX).


In addition to impacts on RDX cleanup,  the IRIS evaluation ignores cancer assessment guidelines published by EPA in the 2005 Federal Register. This has the potential to broadly undermine cancer evaluations. 


The IRIS RDX evaluation likely pleased DOD and ACC who were present at the May public meeting.  The IRIS program director said after the meeting that EPA had consensus among the stakeholders.  But he made no mention of the dissenting comments by Dr. Melnick, nor have the dissenting comments been acknowledged to date.


The zeal of IRIS management to get evaluations "out the door" to avoid further censure should not result in skewed science that panders to special interests.  It should not ignore the public's need for protection from cancer-causing chemicals.  Public interests should at least be acknowledged, even though their voices don't have the political volume of the DOD or ACC.