Dear Chairman Barrasso and Ranking Member Carper:

On behalf of our millions of members and the American people, the undersigned 109 organizations urge you to stand up for our health and environment by opposing the nomination of Dr. Michael Dourson for the position of Assistant Administrator for Chemical Safety and Pollution Prevention of the Environmental Protection Agency.

The job of the Assistant Administrator is to lead the office whose mission is to protect American families and the environment from the potential risks of pesticides and toxic chemicals. This position will shape the way that the United States manages its environmental and chemical programs and thus will have a significant effect on the lives of millions of Americans. In particular, the next Assistant Administrator will be responsible for implementing and enforcing the laws designed to safeguard our health from toxic chemicals. This includes the Toxic Substances Control Act (TSCA), recently updated and amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act. The new law was signed on June 22, 2016 with the intention and hope that the updated requirements would be a beacon for change in the management of toxics and chemical safety.

Implementation of the 2016 TSCA amendments is a significant and challenging task. It must be undertaken by someone who not only demonstrates through their actions and accomplishments a commitment to human and environmental health, but also by someone who is committed to implementing and enforcing the law as written without influence from the regulated industries that may have an interest in seeing the law weakened or poorly enforced. Dr. Dourson’s background indicates that he is not the person for this job.  

Dr. Dourson’s work consulting for the chemical industry during the last few decades raises significant concerns. First, he has a history of serving the interests of big business and industry dating back to the inception of the non-profit he founded and directed, Toxicology Excellence for Risk Assessment (TERA). Examples of TERA’s questionable bias include:

  • In 1997, Dr. Dourson was hired by the Center for Indoor Air Research, which was later disbanded by a judge who found it to be a tool to bolster the credibility of tobacco products, to produce a report on the effects of secondhand smoke, which is known to cause cancer even in people who don’t smoke. The report downplayed the effects by reporting that nonsmokers in the workplace have minimal exposures to secondhand smoke.
  • In 2002, DuPont sought out Dr. Dourson’s firm TERA to recommend to West Virginia’s Department of Environmental Protection a “safe” level for perfluorooctanoic acid (PFOA), a chemical made by DuPont and linked to cancer, thyroid disease, and obesity. His firm recommended a level that, as reported in The Intercept, was “150 times higher than the maximum safety level DuPont’s own scientists had determined in 1988 —1 [part per billion] — based on internal company research showing that PFOA was toxic to both workers and lab animals.” The EPA later conducted its own assessment which determined a level that was thousands of times more protective than TERA’s recommended level. PFOA has also contaminated rivers and drinking water in Ohio, Michigan, New York, North Carolina, Pennsylvania, Vermont, West Virginia and other communities around the country.
  • An email revealed in The Intercept demonstrates how chemical companies hired Dr. Dourson to “bless” their dangerous chemicals:

While everyone had a few names to offer, the common theme that emerged was that TERA (i.e. Mike Dourson) was the leading choice. TERA had “a very good reputation among the folks that are still in the business of blessing criteria,” [DuPont employee Timothy] Bingman explained, going on to describe the company’s ability to “assemble a package and then sell this to EPA, or whomever we desired.”

-“Trump’s EPA Chemical Safety Nominee Was in the ‘Business of Blessing’ Pollution”, The Intercept, July 21, 2017.

  • In 2013 Dr. Dourson was hired by Koch Industries to produce a study that found no adverse health effects to residents in Chicago who were concerned about piling amounts of petroleum coke (petcoke) from Koch subsidiary KCBX Terminals. Dr. Dourson’s findings were based on soil studies and use of KCBX air monitors showing that petcoke soil is no different in the neighboring community than baseline levels in the rest of Chicago, and that the level of air contaminants are not likely to cause health effects. However, research by the city of Chicago and residents’ own documentation of petcoke on their properties contradicted Dr. Dourson’s findings. A class action lawsuit was ultimately settled for $1.4 million.
  • Dr. Dourson also published a report in 2014 entirely funded by a polluting company to study 1,4 dioxane, one of the first ten chemicals being reviewed under the revised TSCA by the office he has been nominated to lead. PPG Industries, responsible for discharging the chemical and contaminating Ohio’s waterways, hired Dr. Dourson to publish a paper on the chemical. The paper argued for an acceptable level of 1,4 dioxane that is 1,000 times higher than EPA’s drinking water guidelines. The methodology Dr. Dourson used in his assessment of 1,4 dioxane was rejected by a panel convened by the state of Michigan.

We are not only concerned about Dr. Dourson’s ties to the chemical and tobacco industries, but by the role he played in presenting industry-biased science in a seemingly neutral manner to alleviate concerns about their products. For example, Dr. Dourson administered a website designed for parents called “Kids + Chemical Safety” that minimized the concern of chemical risks using chemical industry talking points. Another example of downplaying concerns about chemical risks includes the “Tox Topics” webpage of the Toxicology Education Foundation, led by Dourson and funded by companies like Chevron, ExxonMobil, 3M, and the chemical industry’s trade association.

The importance of this job is best defined by the imperative to protect our health. This is made clear by tragic personal stories including the West Virginia residents who lost their drinking water due to the 2014 Elk River Spill; the parents in Flint, MI worrying about the effects of the lead in their water on the IQ and brain development of their children; the farmworkers in Bakersfield, CA poisoned by chlorpyrifos; and the family of 18-year-old Jonathan Welch who died on the job from exposure to methylene chloride. Whether and how potentially dangerous chemicals enter the marketplace is a matter of life and death. We can’t leave those decisions to someone with Dr. Dourson’s history of close ties to the chemical industry.

As organizations committed to the health of the American people, we are deeply concerned with the nomination of Dr. Dourson as the Assistant Administrator.

We need and deserve an Assistant Administrator for EPA’s toxics office who will put public health first, without favoring the industry that the office is charged with regulating.  We urge you to oppose the nomination of Mr. Dourson and insist on a nominee with an unblemished record of defending the health of the American people from the hazards of toxic chemicals.



5 Gyres

Alaska Community Action on Toxics

Alliance for Appalachia

Alliance of Nurses for Healthy Environments

As You Sow

Asbestos Disease Awareness Organization

Blue Green Alliance

Breast Cancer Action

Breast Cancer Prevention Partners

Build A Better Planet

Cape Fear River Watch

Capital District Against Fracking

Catskill Mountainkeeper

Center for Environmental Health

Center for Health, Environment & Justice

Center for International Environmental Law

Central California Environmental Justice Network

Citizens’ Environmental Coalition

Clean and Healthy New York

Clean Production Action

Clean Water Action

Clean Water Action California

Clean Water Action Connecticut

Clean Water Action Massachusetts

Clean Water Action Minnesota


Coalition for Clean Air

Collaborative on Health and the Environment

Coming Clean

Comit Civico del Valle

Communications Workers of America

Community Food and Justice Coalition

Conservation Minnesota

Conservation Voters for Idaho

Cook Inletkeeper

Del Amo Action Committee

Democracy Initiative


Ecology Center

Empire State Consumer Project

Environmental Advocates of New York

Environmental Health Strategy Center

Environmental Justice and Health Alliance

Environmental Working Group

Farmworker Association of Florida

Farmworker Justice

Food & Water Watch

Fresnans against Fracking

Friends of the Earth

Global Alliance for Incinerator Alternatives (GAIA)

Grassroots Environmental Education

Great Neck Breast Cancer Coalition

Green Inside and Out

Greenaction for Health and Environmental Justice



Headwater LLC

Health Care Without Harm

Health Professionals and Allied Employees

Healthy Building Network

Healthy Legacy Coalition

Healthy Schools Network

Hillsborough Clean Investment Coalition

Hip Hop Caucus

Huntington Breast Cancer ACTION Coalition, Inc

International Center for Technology Assessment

League of Conservation Voters

Learning Disabilities Association of America

Learning Disabilities Association of Georgia

Learning Disabilities Association of Illinois

Learning Disabilities Association of Maine

Learning Disabilities Association of New Jersey

Learning Disabilities Association of South Carolina

Learning Disabilities Association of Tennessee

Lenape Indian Tribe of Delaware

Los Jardines Institute

Marin City Parent Academy

Natural Resources Defense Council

NC Child

Nontoxic Certified / Made Safe

North Carolina Conservation Network

Northwest Atlantic Marine Alliance

Oregon Environmental Council

Organize Florida

People for Clean Air & Water of Kettleman City

Pesticide Action Network

Physicians for Social Responsibility


Safer Chemicals Healthy Families

Safer States

San Francisco Firefighters Cancer Prevention Foundation

Science and Environmental Health Network

Sierra Club

Stupid Cancer, Inc.

Texas Campaign for the Environment

Texas Environmental Justice Advocacy Services (TEJAS)

The Environmental Justice Coalition for Water

The Institute of Neurotoxicology and Neurological Disorders (INND)

The Progressive Hub, Saratoga

Toxic-Free Future

Toxics Action Center Campaigns

Tri-County Watchdogs

Tri-Valley CAREs

United Steelworkers

Utility Workers Union of America

Vermont Conservation Voters

Vermont Public Interest Research Group (VPIRG)

WE ACT for Environmental Justice

West Berkeley Alliance for Clean Air and Safe Jobs

Women’s Voices for the Earth