Selected tag(s): DuPont

ACC on Safe Chemicals Act of 2011: If you can’t say anything nice …

Richard Denison, Ph.D., is a Senior Scientist.

The Consumer Specialty Products Association found some nice things to say about it.  DuPont did too.  Even the National Petrochemical & Refiners Association acknowledged some improvements.

And the American Chemistry Council?  Read More »

Posted in Health Policy, TSCA Reform| Also tagged , , , | Comments are closed

EPA's right-to-know effort declassifies the chemicals in 42 health and safety studies

Richard Denison, Ph.D., is a Senior Scientist.

EPA has just released today the full versions — showing the identities of the chemicals in question — of 41 "substantial risk" notices of health and safety studies it had previously received from companies that had denied the public's right to know those identities by claiming them to be confidential business information (CBI).  These notices had been submitted pursuant to Section 8(e) of the Toxic Substances Control Act (TSCA).  One additional notice of a health and safety study that EPA had received under Section 8(d) of TSCA was also released today with its chemical identified.

What's most significant about today's posting is that it makes publicly available the identities of chemicals associated with health and safety data that:

  1. the submitting companies themselves believed the data “reasonably supports the conclusion that [the chemical] presents a substantial risk of injury to health or the environment;” and
  2. should have been publicly available all along, based on the plain language of TSCA that disallows health and safety studies to be claimed CBI in the first place.

Read More »

Posted in EPA, Health Policy, Regulation| Also tagged , , | Read 2 Responses

Raising the bar for chemical safety will spur, not stifle, innovation

Richard Denison, Ph.D., is a Senior Scientist.

An emerging chemical industry talking point in TSCA reform is the claim that imposing new requirements on new chemicals will somehow stifle innovation.  The milder manifestation of this perspective emanates from those who oppose requiring a safety determination for new chemicals unless they raise major red flags in an initial review.

But some in the industry go further, arguing that even requiring safety data for new chemicals would put the big chill on development of new chemicals.

I beg to differ with both arguments.  This post will make the opposite case, and will also argue that true innovation embraces rather than shuns safety, and demands the information needed to demonstrate it. Read More »

Posted in Health Policy, Regulation, TSCA Reform| Also tagged , , , , , , , , , , , | Read 5 Responses

EPA IG report: New Chemicals Program fails to assure protection

Richard Denison, Ph.D., is a Senior Scientist.

In a post to this blog nearly a year ago, I noted that many voices in the chemical industry were claiming that EPA’s New Chemicals Program (NCP) was robust and served as an excellent model for TSCA reform.  My post took considerable issue with that point of view, noting the many structural constraints TSCA imposes on EPA in its effort to review new chemicals:

  • No data, no problem: No up-front testing requirement or minimum data set applies to new chemicals.
  • Guessing game: EPA is forced to heavily rely on limited models and methods to predict the toxicity or behavior of a new chemical.
  • Catch-22: While EPA can require testing of a new chemical on a case-by-case basis, it must first show the chemical may pose a risk – not an easy task without any data in the first place!
  • One bite at the apple: EPA typically gets only a single opportunity to review a new chemical.
  • Crystal-ball gazing: EPA has to try to anticipate a new chemical's for-all-time future production and use.
  • Black box: New chemical reviews lack transparency.
  • Anti-precaution: In deciding whether to require testing or controls for a new chemical, EPA equates lack of evidence of harm with evidence of no harm.

Lately, I’ve been hearing chemical industry representatives trying to resuscitate the NCP-as-model-for-TSCA-reform mantra.  So it is especially timely that a new report from EPA’s Office of Inspector General (OIG) has just been released that again thoroughly dismantles that notion.  The new report’s critique of the NCP closely mirrors the appraisal I provided earlier.  And adding weight to its analysis is the fact that EPA’s senior management has fully concurred with the report’s conclusions and recommendations. Read More »

Posted in Health Policy, Regulation| Also tagged , , | Read 2 Responses

Yes, Virginia, inhaled carbon nanotubes do cause lung granulomas

Richard Denison, Ph.D., is a Senior Scientist.

My last post identified two Section 8(e) "substantial risk" notices pertaining to carbon nanotubes, one submitted by BASF, the other by Arkema.  I have in my files one additional Section 8(e) notice for a single-walled carbon nanotube (SWCNT), submitted by DuPont.  With three Section 8(e) notices submitted for different rat pulmonary toxicity studies on carbon nanotubes, it's interesting to compare their results. Read More »

Posted in Health Science, Nanotechnology| Also tagged , , | Comments are closed

Shining a (partly shaded) light on nanomaterials that present "substantial risk"

Richard Denison, Ph.D., is a Senior Scientist.

Section 8(e) of the Toxic Substances Control Act (TSCA) requires any company that manufactures, imports, processes or distributes chemicals in the U.S. to notify EPA within 30 days if it obtains new information that "reasonably supports the conclusion that such substance or mixture presents a substantial risk of injury to health or the environment."  Are there Section 8(e) notices for nanomaterials? Read More »

Posted in Health Policy, Regulation| Also tagged , | Comments are closed
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