EDF Health

Selected tag(s): IUR/CDR

Public health advocates to the chemical industry: Stop hobbling EPA

Richard Denison, Ph.D., is a Senior Scientist.  Allison Tracy is a Chemicals Policy Fellow.

Today, EDF joined with 32 other environmental justice, health and environmental organizations to file comments [PDF] with EPA that strongly support its effort to improve its ability to obtain – and share with the public – robust information about the production, processing and use of chemicals in the U.S.

While the details of EPA’s proposed rule and many of our comments are heavily wonky, the motivation and goals are far from it:  To make sure that EPA, the marketplace and the public have the information they need to guard against harm from dangerous chemicals.  That requires knowing a whole lot more than we do today about what chemicals are in commerce, in what quantities, how they’re used – essential to understanding how we may be exposed.

Robust information is the lifeblood of a sound chemicals management system.  Government needs access to comprehensive, reliable information to inform policy, programmatic and regulatory decisions it must make to carry out its mission.  The market needs access to such information to inform the myriad decisions made every day by producers, sellers and users of chemicals and products and materials made using chemicals.  And researchers, the public and groups that work in the public interest need access if they are to have confidence in, and be able meaningfully to contribute to, decisions and actions taken by government and the private sector.

In an earlier post, we made the point that the chemical industry’s reactions to these modest proposals will be a litmus test for how serious it is in acting on its rhetoric about the need for EPA and the public to have more and better information on chemicals.  With the comment period closing today for EPA’s proposed rule, look here in the coming weeks for our assessment on industry’s comments.

What follows is a summary of our comments, indicating both what we support and what more is needed.  Read More »

Posted in Health policy, Industry influence, Regulation / Also tagged , , | Comments are closed

EPA seeks to improve TSCA data reporting; a real litmus test looms for the chemical industry

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

While I was on vacation last week, EPA’s proposed rule to improve chemical information reporting under its so-called Inventory Update Rule (IUR) was finally published in the Federal Register.  (I say “finally” because the proposal languished for almost 6 months over at OMB, nearly double the 90 days such mandatory reviews are supposed to take.  That unfortunate delay is curious given the relatively modest changes that appear to have been made by OMB – mostly limited to compelling EPA to shift a few elements from proposals to options open to comment, and requiring EPA to expand the range of issues on which it now seeks comment.)

I won’t summarize the EPA proposals here; EPA’s factsheet does a good job of that, and Daniel Rosenberg at NRDC has also nicely recapped the proposal on his blog.  Suffice it to say that the proposed changes would go far to address the many failings of the current IUR, which amply manifested themselves in the last reporting cycle and severely hampered EPA’s ability to assess high production volume (HPV) chemicals under its ill-fated ChAMP Initiative.

So how will the chemical industry react?  Here’s why I’ll be watching intently.  Read More »

Posted in Health policy, Regulation / Also tagged , , , , , , , , , | Read 1 Response

Worse than we thought: Decades of out-of-control CBI claims under TSCA

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

I recently obtained – not without some effort on both EPA’s and my part – a scanned copy of a 1992 report commissioned by EPA innocuously titled “Influence of CBI Requirements on TSCA Implementation,” authored by the now-defunct Hampshire Research Associates.  I subsequently found a copy in an old EPA docket, located here (6 MB PDF file).

This understated yet remarkable report is a veritable treasure trove of information that painstakingly documents the rampant rise in illegitimate confidential business information (CBI) claims made by the chemical industry in the first decade after passage of the Toxic Substances Control Act (TSCA) – and the very limited options available to EPA to stop such activity (despite recent admirable efforts on its part). Read More »

Posted in Health policy, Regulation / Also tagged , , | Read 2 Responses

ChAMP “superseded”: EPA shifts into action mode

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

A new entry showed up sometime in the last day on EPA’s webpage for its ChAMP initiative.  It reads:  “The Chemical Assessment and Management Program (ChAMP) has been superseded by the comprehensive approach to enhancing the Agency’s current chemicals management program announced by Administrator Lisa Jackson on September 29, 2009.”

Don’t miss this bit at the top of the page:cobweb

Yes, that image is a cobweb, which EPA uses to designate archived web content.  What’s happening here? Read More »

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O Canada!

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

Some time back, I promised a look at whether Canada’s Chemical Management Plan provides a model for TSCA reform.  This post will provide that look.  Bottom line:  While our neighbor to the north has undertaken and accomplished a great deal over the past decade, it has done so with one hand tied behind its back.  Read More »

Posted in Health policy, International, TSCA reform / Also tagged , , , , , | Read 4 Responses

ChAMP’s double standard

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

This new post serves as a response to Charlie Auer’s most recent comment responding to our critique of ChAMP.  (To see the whole exchange, start here, then go here, here and here.)  So far, this exchange has focused mainly on our disagreement over whether or not EPA is somehow required to do risk assessments under ChAMP.  At some point, I hope Charlie and others will engage on the substance of our critique – the serious concerns we’ve raised about the quality and validity of the ChAMP assessments.
Read More »

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