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ARTICLE · 14 APRIL 2022

Microplastics In The Lungs: The Next Asbestos Or Are We Just Catastrophizing?

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Two developments this week got me thinking about how our government deals – or fails to deal – with risk.

United StatesEnvironment
Seth Jaffe
Seth Jaffe
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Two developments this week got me thinking about how our government deals – or fails to deal – with risk.  First, EPA proposed to ban the manufacture (including import) of chrysotile asbestos.  EPA's authority for doing so is the Toxic Substances Control Act which provides that:  

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if EPA determines through a TSCA section 6(b) risk evaluation that a chemical substance presents an unreasonable risk of injury to health or the environment, without consideration of costs or other non-risk factors, under the conditions of use, EPA must by rule apply one or more requirements to the extent necessary so that the chemical substance or mixture no longer presents such risk.

One might ask – and I do – how one determines what constitutes an "unreasonable" risk, without consideration of cost.  If cost is irrelevant, wouldn't any risk be "unreasonable"? I am not suggesting that the proposed rule is inappropriate.  I don't know the science.  I just don't see how rational

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