How DOGE Can Help EPA: Proposing a Fourth Reform — Improving Agency Efficiency
President-elect Trump’s proposed (and aspirational) Department of Government Efficiency (DOGE) is the latest incarnation of a new Administration’s attempt to leave its mark on the federal government. In the November 20, 2024, Wall Street Journal, Elon Musk and Vivek Ramaswamy published an Op-ed about the DOGE effort they will lead and the three kinds of reform DOGE will pursue: regulatory recissions, administrative reductions, and cost savings. We propose that DOGE add a fourth, equally important focus, to improve the efficiency and productivity of federal agencies, especially the U.S. Environmental Protection Agency (EPA).
With nearly everything in commerce, from autos to electronics, touched by chemistry, improving the process by which EPA evaluates industrial chemicals would be significant. EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP) is charged with conducting safety reviews of existing products and is the gatekeeper for new products. If DOGE can identify ways to improve the operation and efficiency of OCSPP (e.g., by ensuring appropriate resources and updated technology), this could lead to economic gains, greater investment, innovation, and sustainability, and yes, more jobs in the United States.
Most chemicals enter commerce in the United States after government review and approval under statutes such as the Toxic Substances Control Act (TSCA) and agricultural chemicals under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), both of which are managed by OCSPP. Research commissioned by the Coalition for Chemical Innovations shows a significant drop off in applications for approval of new chemicals under TSCA and a significant reduction in company spending on research and development. If a company cannot gain approval to manufacture a chemical in the United States, it goes elsewhere. The average time for EPA to review a new chemical application has risen from 472 days in 2021 to 674 days in 2024, while the number of submissions has dropped from 251 in 2021 to 182 through October (on pace for 218) in 2024. OCSPP is hampered by aging software and hardware, and the lack of specific, written guidance on how it is to review cases.
When EPA takes two, three, or in several cases, over eight years to make a decision, companies commercialize these new, innovative, and often more sustainable chemistries outside the United States, including in Asia and Europe. These crushing delays cause promising innovators to stop trying to commercialize new chemistries in the United States under TSCA. Either way, the United States loses — on innovation, jobs, new products, and more sustainable products.
Under FIFRA, EPA also routinely misses its deadlines under the Pesticide Registration Improvement Act (PRIA). A computer system’s problem in 2023 led to significant delays in thousands of PRIA and other actions. OCSPP is still working through many of those cases as they struggle with new submissions. Staff shortages and inexperienced staff in the pesticides office also hamper efficient operations.
Workforce issues are one aspect of improving efficiency. Having and using current technology is another. In their Op-ed, Musk and Ramaswamy write that DOGE will be “… aided by advanced technology …” to follow its mandate. We urge DOGE to consider how deploying advanced technology in federal agencies such as EPA also will contribute to improved efficiency. OCSPP needs to be adequately staffed and equipped with current technology to evaluate properly chemicals and pesticides in a timely, consistent, predictable, and scientifically and legally supportable manner. Cutting or gutting OCSPP will exacerbate, not relieve, the much-delayed reviews under TSCA and FIFRA and further drive chemical innovation overseas.
The products that rely on new, innovative, and sustainable chemistries will benefit greatly if DOGE were able to expand its mission by adding “improve the efficiency and productivity of federal agencies.” The innovations are here, waiting for OCSPP to act. Help them get into commerce by supporting OCSPP and boost U.S. manufacturing in the process.