ATTORNEY GENERAL RAOUL LEADS COALITION OPPOSING EPA’S PROPOSAL TO WEAKEN RISK ASSESSMENT OF CHEMICAL SUBSTANCES

ATTORNEY GENERAL RAOUL LEADS COALITION OPPOSING EPA'S PROPOSAL TO WEAKEN RISK ASSESSMENT OF CHEMICAL SUBSTANCES

November 07, 2025

Chicago - Attorney General Kwame Raoul today led a coalition of 17 attorneys general opposing the U.S. Environmental Protection Agency's (EPA) proposal to roll back several critical requirements for evaluating the risk of chemical substances under the Toxic Substances Control Act.

The statute requires the EPA to evaluate the risks of chemical substances under circumstances for which exposures could be reasonably foreseen. However, the EPA's proposed rule change would allow the agency to omit certain uses of chemical substances from its evaluation and, without explanation, to consider other uses in isolation, instead of considering their overall effect.

"The U.S. Environmental Protection Agency is required to conduct a comprehensive review of the risk of health and environmental harms associated with chemical substances regulated under the Toxic Substances Control Act," Raoul said. "The EPA's proposed rule changes would eliminate this holistic approach to evaluating risk, potentially allowing for these substances to be used in ways that endanger public health and the environment. I remain committed to protecting important environmental regulations that keep us safe and protect our natural resources."

In their comment letter opposing the proposed rule changes, Raoul and the attorneys general argue that the agency could fail to consider the total risk and impact associated with combined chemical exposures through separate types of use. In addition, they warn that the changes could lead to regulators, without explanation, not considering the possibility of significant and harmful aggregate effects that can add up over time from many different exposures. The administration's proposed rule changes would also undermine consideration of the effects of chemical substances on overburdened communities that disproportionately face environmental and public health threats, as well as workers who could be exposed to chemical substances on the job. The coalition writes that this change would put residents of their states at risk, and they call on the administration to take steps to more fully assess risks from chemical substances to overburdened communities and communities with environmental justice concerns.

The coalition also asserts that the proposed rule changes are arbitrary and capricious and based on unexplained and unsupported changes in the EPA's interpretation of its statutory authority.

Joining Attorney General Raoul in filing the comments are the attorneys general of Connecticut, the District of Columbia, Hawaii, Maine, Maryland, Michigan, Minnesota, New Jersey, New York, Oregon, Rhode Island, Vermont, Washington, and Wisconsin, as well as the Corporation Counsel of the City of New York.