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Comments to EPA on its Proposed Asbestos Risk Management Rule

The Environmental Protection Agency (EPA) has proposed a ban on multiple conditions of use of chrysotile asbestos. The Institute for Policy Integrity and Professor Rachel Rothschild at the University of Michigan Law School submitted comments on the agency’s economic analysis of the proposed rule, identifying numerous ways EPA underestimated the health benefits from reduced cancer cases and lung illnesses.

Policy Integrity recommends that EPA conduct its baseline benefits analysis without assuming use of personal protective equipment, incorporate additional populations at risk of asbestos exposure, and evaluate the rule over a longer timeframe to better capture its full benefits. We also encourage the agency to place greater emphasis on the expected benefits as calculated under a 3% discount rate, which is more consistent with current economics literature on appropriate discount rates for long latency harms. Additionally, we recommend adjusting the expected value from avoided cancer harms upwards to reflect increases in GDP per capita that would occur over the latency period and relying more heavily on the anticipated net benefits under the caustic soda revenue gain scenario. Finally, Policy Integrity made broader suggestions regarding EPA’s approach to conducting cost-benefit analyses of TSCA risk management rules, such as including all relevant exposure pathways. These changes will further strengthen the robust scientific, economic and legal basis for EPA’s proposed rule.

In addition to our main comments, Policy Integrity also submitted a second set of comments on EPA's use of the social cost of greenhouse gases when calculating the climate benefits of the rule. These comments provide support for the agency’s decision to apply the social cost estimates developed by the Interagency Working Group on the Social Cost of Greenhouse Gases in a sensitivity analysis that monetizes the greenhouse gas emissions reduction benefits resulting from the proposal.