_{Profile image from David Dunlap’s profile at the United States Environmental Protection Agency website.}

David Dunlap

Credentials

B.S. Chemical Engineering, Virginia Tech (1984)¹

Background

David Dunlap is the vice president of global government relations at Harsco Corporation² . From September-October 2018 to January 2021, Dunlap was the Trump administration’s second Deputy Assistant Administrator for Research and Development at the U.S. Environmental Protection Agency (EPA), succeeding Richard Yamada.³ ⁴. ⁵

The EPA Office of Research and Development (ORD) conducts key research on chemicals that informs and enables the agency’s development and enforcement of environmental regulations.

Dunlap came to the EPA directly from eight years as the director of policy and regulatory affairs at Koch Industries, a role that “typically includes helping companies to limit regulatory restrictions and liability for cleanups”: ⁶ As Politico reported in early 2019:

“The Trump administration has placed a former Koch Industries official in charge of research that will shape how the government regulates a class of toxic chemicals contaminating millions of Americans’ drinking water — an issue that could have major financial repercussions for his former employer.

“David Dunlap, a deputy in EPA’s Office of Research and Development, is playing a key role as the agency decides how to protect people from the pollution left behind at hundreds of military bases and factories across the country.”

At the time of Dunlap’s appointment, President Donald Trump had not nominated anyone to lead the ORD, a position that requires Senate confirmation. This put Dunlap in a powerful position – which did not need to be confirmed by the Senate – to oversee “a central part of EPA‘s work that could impose cleanup costs on companies that have used the chemicals, including major Koch subsidiary Georgia-Pacific.”⁷

Trump often used this tactic of appointing deputy officials to agencies with vacant top leadership roles – called “delegation” – to evade Senate confirmation hearings. “With delegation, there’s no time limit,” reported NPR. “A subordinate can effectively take on the boss’s responsibilities indefinitely.”⁸

On his LinkedIn profile, Dunlap described his work at Koch Industries as drawing on his “subject matter expert[ise]” on water and waste water in relation to the Safe Drinking Water Act and the Clean Water Act, and chemical management in relation to the Toxic Substances Control Act (TSCA).⁹

In a press release, Environmental Working Group president Ken Cook said that Dunlap “was installed at the EPA because Charles and David Koch wanted one of their own in a position of influence inside the agency they despise the most.”¹⁰

Prior to Koch Industries, Dunlap worked at the Chlorine Institute, a trade association for chlorine producers and distributors.¹¹

Political Contributions

According to data from the Federal Elections Commission, Dunlap consistently contributed to the Koch Industries Political Action Committee, including contributions in 2010, 2014, 2016, 2017, and 2018.¹²

Stance on Climate Change

David Dunlap does not appear to have publicly described his views on climate change.

Key Quotes

David Dunlap does not appear to have published any articles, or have any recent statements attributed to him.

Key Deeds

February 2019

In February 2019, Politico reported that within weeks of taking his job, Dunlap was involved in at least nine high-level meetings regarding levels in drinking water of per- and polyfluoroalkyl substances, or PFAS. These chemicals are “linked with kidney and testicular cancer, as well as other ailments.” EPA did not establish safe PFAS levels in drinking water during Dunlap’s tenure. ¹³ ¹⁴ ¹⁵

December 2018

In David Dunlap’s recusal statement,¹⁶, obtained by E&E News, Dunlap said that he would not participate in activities related to the EPA risk assessment for formaldehyde:¹⁷

“Although not necessarily required, I am voluntarily recusing myself from participation in any matters related to the formaldehyde IRIS assessment for the duration of my EPA tenure in order to avoid the appearance of any ethical concerns in my role as Deputy Assistant Administrator.”

September/October 2018

Politico reported that the Trump administration had appointed David Dunlap as Deputy Assistant Administrator for Research and Development at the EPA. “As a chemical engineer, Mr. Dunlap has worked on environmental issues for nearly 30 years with a focus on assessing risk,” EPA chief of staff Ryan Jackson said in a statement. “His extensive experience on regulatory issues will be pivotal in our mission to protect human health and the environment.” According to Dunlap’s LinkedIn, he joined the EPA in September 2018.¹⁸ ¹⁹

2017

David Dunlap was listed as an industry representative to an EPA committee negotiating a proposed rule to limit chemical data reporting (CDR) requirements under the Toxic Substances Control Act. Dunlap was listed as affiliated with Koch Companies Public Sector, LLC, and representing American Fuel & Petrochemical Manufacturers, a national trade association representing 98 percent of oil refining capacity in the United States. ²⁰

2013

Dunlap, representing Koch Companies Public Sector, was listed as a delegate to the 2013 GlobalChem Conference hosted by the American Chemistry Council, a lobby group for the chemical industry, and the Society of Chemical Manufacturers and Affiliates (SOCMA).²¹

January 20 – 21, 2011

David Dunlap, representing Koch Companies Public Sector, attended an EPA meeting regarding “Mortality Risk Measurement and Valuation for Policy Analysis.” The meeting’s agenda involved reviewing a draft of a December 2010 agency white paper titled, “Valuing Mortality Risk Reductions for Environmental Policy,” which included discussion of cancer risks. A representative from the American Petroleum Institute was also listed in meeting minutes and filed comments to the EPA’s Science Advisory Board (SAB) office.²²

2005

According to lobbying disclosure forms filed with Congress, David Dunlap lobbied the EPA‘s Office of Solid Waste and Emergency Response on behalf of the Uniform & Textile Service Association, regarding proposed regulations on hazardous waste management.²³

March 9, 2004

Representing the Uniform & Textile Service Association, David Dunlap testified at an EPA hearing on a proposed rule regarding “conditional exclusions…for solvent-contaminated industrial wipes” from industry hazardous waste reporting. In his testimony, Dunlap defended industrial laundry as more eco-friendly than other options: “Industrial laundries provide environmental benefits by decreasing natural resource consumption, saving energy and providing effective pollution management and prevention.”²⁴

Affiliations

Note: The following information on David Dunlap’s professional affiliations is taken from Dunlap’s LinkedIn profile, and has not been independently confirmed by DeSmog.

Harsco Corporation — Vice president, global government relations (July 2021-present)²⁵
United States Environmental Protection Agency (EPA) — Deputy assistant administrator, Office of Research & Development (September 2018 – January 2021)²⁶
Koch Industries — Director of Policy and Regulatory Affairs (May 2010 – August 2018)²⁷
The Chlorine Institute — Vice president of Health, Environment, Safety and Security (May 2006 – May 2010)²⁸
Uniform & Textile Service Association — Director of Government and Environmental Affairs (May 1995 – May 2006)²⁹
Ogden Environmental — Manager, Hazardous Materials Department (October 1987 – May 1995)³⁰
Lapteff Associates — Project engineer and wastewater treatment plant manager (November 1984 – October 1987)³¹

David Dunlap on LinkedIn

Publications

Other Resources

“Drinking Water PFAS Contamination Crisis: Ex-Koch Chemicals Executive Playing Key Role in Shaping EPA‘s Response,” EcoWatch, February 5, 2019

Resources

1
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.
2
“David Dunlap,” LinkedIn. Archived March 21, 2023 Archive URL: https://archive.ph/wip/JbVWY
3
“David Dunlap,” United States Environmental Protection Agency. Archived March 6, 2019. Archive.fo URL: https://archive.fo/J1XBH
4
“Former Koch official runs EPA chemical research,” Politico, February 4, 2019. Archived March 6, 2019. Archive.fo URL: https://archive.fo/AFtDa
5
Brandi Buchman. “EPA Names Former Koch Industries Figure Chief of Research,” Courthouse News, October 1, 2018. Archived March 21, 2023. Archive URL: https://archive.is/t4avZ
6
“Former Koch official runs EPA chemical research,” Politico, February 4, 2019. Archived March 6, 2019.
7
“Former Koch official runs EPA chemical research,” Politico, February 4, 2019. Archived March 6, 2019. Archive.fo URL: https://archive.fo/AFtDa
8
Joel Rose. “How Trump Has Filled High-Level Jobs Without Senate Confirmation Votes,” NPR, March 9, 2020. Archived March 9, 2020. Archive URL: https://archive.is/wxyvw
9
Brandi Buchman. “EPA Names Former Koch Industries Figure Chief of Research,” Courthouse News, October 1, 2018. Archived March 21, 2023. Archive URL: https://archive.is/t4avZ
10
(Press Release). “After Axing Key Science Office, Trump Puts Ex-Koch Exec in Charge of Research at EPA,” EWG, October 2, 2018. Archived March 6, 2019. Archive.fo URL: https://archive.fo/XdhQq
11
“David Dunlap,” LinkedIn. Archived March 21, 2023 Archive URL: https://archive.ph/wip/JbVWY
12
“Individual contributions,” Federal Election Commission. Data retrieved March 6, 2019.
13
E.A. Crunden. “Former Koch staffer appointed to key EPA position,” ThinkProgress, October 2, 2018. Archived March 6, 2019. Archive.fo URL: https://archive.fo/3Vvp8
14
“Former Koch official runs EPA chemical research,” Politico, February 4, 2019. Archived March 6, 2019. Archive.fo URL: https://archive.fo/AFtDa
15
E.A. Crunden. “Former Koch staffer appointed to key EPA position,” ThinkProgress, October 2, 2018. Archived March 6, 2019. Archive.fo URL: https://archive.fo/3Vvp8
16
“Recusal Statement” (PDF), United States Environmental Protection Agency, December 19, 2017. Retrieved from E&E News. Archived .pdf on file at DeSmog.
17
Kevin Bogardus. “Ex-Koch official steps away from formaldehyde study,” E&E News, December 27, 2018. Archived March 6, 2019. Archive. fo URL: https://archive.fo/8BVUE
18
Darius Dixon. “Senate to run LWCF revival,” Politico, October 2, 2018. Archived March 6, 2019. Archive.fo URL: https://archive.fo/fYrty
19
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.
20
“OPERATING PROTOCOL OF THE NEGOTIATED RULEMAKING COMMITTEE TO NEGOTIATE A PROPOSED RULE TO LIMIT CHEMICAL DATA REPORTING (CDR) REQUIREMENTS UNDER SECTION 8(A) OF THE TOXIC SUBSTANCES CONTROL ACT (TSCA)” Environmental Protection Agency. Draft as of 6/21/17. Archived .pdf on file at DeSmog.
21
“2013 Conference Delegates List” (PDF), Chemical Watch, 2013. Archived .pdf on file at DeSmog.
22
“Summary Minutes of the U.S. Environmental Protection Agency (EPA) Science Advisory Board (SAB) Environmental Economics Advisory Committee (EEAC) Augmented for Valuing Mortality Risk Reduction Public Meeting” (PDF), Environmental Protection Agency, January 20, 2011. Archived .pdf on file at DeSmog.
23
LOBBYING REPORT for Uniform & Textile Service Association, 2005. Archived March 7, 2019. Archived .pdf on file at DeSmog.
24
“HAZARDOUS WASTE MANAGEMENT SYSTEM: : IDENTIFICATION AND LISTING OF : HAZARDOUS WASTE: CONDITIONAL : EXCLUSIONS FROM HAZARDOUS WASTE : AND SOLID WASTE FOR SOLVENT- : CONTAMINATED INDUSTRIAL WIPESPROPOSED RULE” (PDF), March 9, 2004. Retrieved from the Washington Post. Archived March 21, 2023. Archive URL: https://archive.ph/wip/tROej.
25
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.
26
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.
27
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.
28
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.
29
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.
30
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.
31
“David Dunlap,” LinkedIn. September 2022. Archived .pdf on file at DeSmog.

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David Dunlap

David Dunlap

Credentials

Background

Political Contributions

Stance on Climate Change

Key Quotes

Key Deeds

Affiliations

Publications

Other Resources

Resources

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DeSmog

David Dunlap

David Dunlap

Credentials

Background

Political Contributions

Stance on Climate Change

Key Quotes

Key Deeds

Affiliations

Social Media

Publications

Other Resources

Resources

Related Profiles

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