The American Industrial Hygiene Association (AIHA) has launched a campaign denouncing staff cuts at the National Institute for Occupational Safety and Health (NIOSH), after the Trump administration told about 90% of NIOSH staff that their jobs are ending.
Cuts at NIOSH, part of a broad effort to shrink federal agencies, could have important consequences for TSCA and other chemical regulations, according to several experts interviewed by Chemical Watch News & Insight.
"The proposed reductions effectively end the institute's ability to conduct essential research and provide guidance," said AIHA CEO Lawrence Sloan.
The AIHA campaign calls on the US Department of Health and Human Services (HHS) to reverse the planned cuts before officially terminating staff in June. As of 15 April, more than 5,000 people have sent messages to Congress through the campaign.
A spokesperson for HHS said that NIOSH and "its critical programmes" will be integrated into a new department called the Administration for a Healthy America.
"This restructuring is intended to support the consistent implementation of safety standards without disruption to ongoing regulatory processes," the spokesperson said.
However, a draft plan leaked on 16 April confirmed that as of last week, the Trump administration is proposing the elimination of most NIOSH programmes, including those that certify personal protective equipment (PPE), develop chemistry methods, train industrial hygienists and research worker safety.
Scientists said that the work of some of those programmes – including several relied on by the TSCA programme – has already been paused.
TSCA ECELs rely on NIOSH methods handbook
One way in which the NIOSH cuts could affect TSCA is by eliminating a programme that EPA uses to establish and enforce chemical exposure limits (ECELs) for hazardous chemicals used in the workplace.
NIOSH has developed the Manual of Analytical Methods, which is used worldwide to standardise measurements across laboratories. According to Frank Hearl, a retired NIOSH chief of staff, the EPA relies on the manual when it decides to set TSCA ECELs rather than banning a chemical entirely.
"If you set an exposure limit, you have to be able to prove that you are above or below that limit," Hearl said. NIOSH develops new methods, and then the TSCA rules incorporate them.
Particularly when the EPA targets low exposure levels, Hearl said, "they’re probably going to need to do some methods development work to get to that level".
The entire team working on the manual received layoff notices, according to Micah Niemeier-Walsh, a spokesperson for a union that represents NIOSH scientists.
"Methods currently in development for chemicals that have proposed or finalised ECELs are now halted," Niemeier-Walsh said. "There will be no updates to methods and no new methods developed by NIOSH if HHS moves forward with these cuts."
Fate of NIOSH Approved PPE unclear
Many TSCA final risk management rules also require NIOSH-approved PPE as part of workplace chemical protection programmes (WCPPs).
Yet all the staff in the NIOSH laboratory that certifies and audits PPE received termination notices, according to three scientists at the laboratory.
Nichole Suhon, a steward with the union representing those scientists, said their work will not be easy to replace. "This is the only location that certifies respirators, period," Suhon said.
Ongoing manufacturer audits have already stopped, and a recent programme to address counterfeit PPE has also been paused, according to Suhon.
NIOSH staff also do not know what to tell manufacturers about the future of the programme or about whether they will be able to continue to sell respirators that have already been certified, Suhon added.
Other TSCA impacts
Hearl said that NIOSH is widely respected as an "honest broker" for gathering real-world risk data that regulatory agencies can lean on in developing rules.
NIOSH workplace site visits, called health hazard evaluations, are often cited in TSCA risk evaluations.
In the 1,3-butadiene draft risk evaluation, for example, the EPA based three occupational exposure scenarios on data collected by NIOSH in collaboration with the Occupational Safety and Health Administration (OSHA).
TSCA risk evaluations also cite NIOSH toxicology research.
Xiaozhong John Yu, a researcher at the University of New Mexico who has studied the neurotoxicity risks of 1-bromopropane, said NIOSH coordinated important follow-up research on the chemical through the National Toxicology Program (NTP).
NIOSH is one of three core agencies providing scientists to that programme.
Looking further ahead, cuts at NIOSH could also have broader implications for the field, given the agency’s historical role in funding university research and sponsoring training programmes for industrial hygienists and occupational epidemiologists.
Apart from two cancer registries and two mandatory worker compensation programmes, the draft HHS budget plan said, "Funding for all other NIOSH programmes is discontinued." Congress will decide whether to accept these funding suggestions.