July 2, 2026EPA Doing Less With Less: slashing science staff; dismissing hazard data; weakening pesticide regulations; compromising health protections

Blog Post

Jennifer Sass, Senior Scientist at the Natural Resources Defense Council

This summer, the U.S. Environmental Protection Agency (EPA) announced that it was expanding its list of “alternative test methods” that could be used to assess the health risks of chemicals, including pesticides, that end up in our air, water and food. Without frameworks in place to prevent backsliding, this will result in weaker health protections from harmful chemicals.

For decades, EPA has relied on a combination of rodent tests to derive dose-response values, epidemiology studies from exposed human populations, most often occupationally exposed workers, to identify specific and sometimes more sensitive effects in people, and cell-based test data to elucidate the chemical’s mechanism or mode of toxicity. Each of these three information streams can provide important and unique evidence:

Rodent tests that are well-conducted and of sufficient statistical power provide a way to test the chemical under controlled conditions, across both sexes and a range of ages and developmental stages, in a complex living mammalian system.
Epidemiology studies provide important information about human risk under real-world conditions, including the complexities of age, health, and exposure to other chemicals.
Cell-based test data - including “alternative” tests known as New Approach Methods, or NAMs tests - can help to understand how the chemical may interfere with cellular processes including causing DNA damage, altering gene regulation, or even causing cell death. Cells in the tests may be from humans, rodents, or other animals.

Like a three-legged stool, integrating available evidence from all three of these information streams can provide a solid supportive scientifically robust basis for chemical hazard evaluations. (Chartres et al. 2025).

However, EPA has now chosen to limp along on the last and weakest leg of the stool, cell-based test data. This would be fine if EPA were willing to restrict toxic chemical exposures - that is, to strengthen human health protections - based on NAMs only. But, it isn’t. Instead, EPA is weakening health protections - raising exposure limits for several toxic pesticides! - based on NAMs, even when rodent data and epidemiology link the chemical or pesticide with harm.

In short, EPA’s one-legged stool approach is alarmingly off-balance.

For example, farmworkers are exposed to many toxic pesticides - that is the reality of their work. EPA should integrate the epidemiology findings of human harm with other streams of evidence to strengthen its overall evaluation, but instead EPA is disregarding epidemiology studies that identify more than one pesticide as causing health harms (Earthjustice 2025; Project TENDR 2024). EPA should take epidemiological studies seriously, because they show that the agency is failing in its duty to keep farmworkers and their families safe from pesticides it is responsible for regulating. Instead, EPA is wrongly dismissing “critical knowledge of what we know about health and disease, risk factors, causation, prevention, and treatment [that] derives from epidemiology.” (Soskolne et al. 2021)

Serious health harms to workers and communities will result if chemicals are misclassified as less hazardous or non-hazardous based on unproved hypotheses, poorly validated tests and incomplete data sets. “Declaring a chemical as not hazardous, or reducing a level of health protection, should require validation, not speculation” (Melnick et al. 2003). Such regulatory failures will most acutely jeopardize the health of workers at the frontlines of chemical exposure, including in fields, factories and beauty salons.

The Trump Administration is justifying its expanded use of NAMs under the guise of taking “new action to eliminate animal testing.” But let’s put this in context. The Trump Administration has fired and reassigned thousands of scientists from EPA. It has eliminated EPA’s central program for testing chemical toxicity (the Integrated Risk information System or IRIS), and cast doubt on EPA’s library of hundreds of existing chemical assessments. And it has stacked EPA leadership with former chemical lobbyists.

Scientists within the Coming Clean network, allied with environmental health professionals and farmworker groups, have been sounding alarm bells about the irresponsible use of NAMs for many years. Now, scientists across our organizations must form a united front against expanded use of NAMs to replace proven science, before more regulatory protections disappear.