Selected tags: Persistent Bioaccumulative and Toxic (PBT)

Avoiding paralysis by analysis: EPA proposes a sensible approach to identifying chemicals of concern

Richard Denison, Ph.D., is a Senior Scientist.  Thanks to my colleagues Jennifer McPartland and Allison Tracy for their analysis of the EPA proposal discussed in this post.

Last week, the Environmental Protection Agency (EPA) held stakeholder meetings to get public input into the criteria it will use to identify additional chemicals of concern beyond the 11 chemicals or chemical classes it has already identified.  EPA used these meetings (as well as an online forum open until September 14) as an opportunity for the public to respond to a “discussion guide” it issued in August that sets forth draft criteria and identifies data sources it intends to use to look for chemicals that meet the criteria.

The day before the EPA meetings, the American Chemistry Council (ACC) issued its own “prioritization tool” which lays out its own criteria and ranking system for identifying chemicals of concern.  This post will make a few observations about EPA’s proposal.  My next post will provide a critique of ACC’s proposed tool.

EDF and the Safer Chemicals Healthy Families coalition strongly support EPA in this endeavor – both for what it is, and for what it is not.    Read More »

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

TSCA reform 2.0, aka, Safe Chemicals Act of 2011: Tastes great, less filling

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

The Safe Chemicals Act of 2011 was introduced in the U.S. Senate today by Senator Frank Lautenberg and is co-sponsored by Senators Amy Klobuchar, Charles Schumer, and Barbara Boxer.

In the TSCA reform debate, some things haven’t changed from last year:  TSCA is just as badly in need of an overhaul, and consumers and the chemical industry’s customers have no more confidence in the safety of chemicals in use today than they did a year ago.  States, other countries and the marketplace all continue to act to advance modern chemical safety policies and practices.  We in the advocacy community are still waiting for the chemical industry to offer some of its own proposals for reform – though some individual companies and product associations have been more forthcoming.

In contrast, the 2011 version of the Safe Chemicals Act has changed in some important ways – and for the better.  It includes a number of improvements over last year’s version that would both boost health protections and ease implementation and workability.

[Updated 5-9-11:  Here's a side-by-side comparing the 2011 version to the 2010 version of the Act.]  Read More »

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

Ripples of REACH: Chemicals policy changes in Japan, Turkey and South Korea

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

The November 31st deadline for the first batch of registrations under REACH (the European Union’s Regulation for Registration, Evaluation, Authorization and Restriction of Chemicals) may have passed, but life is far from dull on the international scene of chemicals policy.  As discussed in a previous post, chemicals policy enhancements are ramping up across the globe, many of them mirroring the innovations introduced under REACH.

In this post, we’ll discuss significant advances in Japan, Turkey and South Korea that drive home the message that the ripples from REACH are ever-widening.  Read More »

Posted in EU REACH, Health Policy, International | Also tagged , , , , , , , | Comments closed

No authorization, no market: REACH identifies first six chemicals to be phased out except for explicitly authorized uses

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

The European Commission today identified the first six chemicals to be made subject to authorization under the European Union’s Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals, or REACH.

The long road to today’s decision began in October 2008, when the European Chemicals Agency (ECHA) identified these chemicals as Substances of Very High Concern (SVHCs) and placed them on its Candidate List for chemicals potentially to be subject to authorization. Under REACH, a chemical qualifies as a SVHC as a result of being:  (1) carcinogenic, mutagenic, or a reproductive toxicant (CMR), (2) being persistent, bioaccumulative and toxic (PBT), (3) being very persistent and very bioaccumulative (vPvB), or (4) being found to “give rise to an equivalent level of concern.”  Clearly these are the types of chemicals we want to pay attention to!

Today’s formal addition of these chemicals to REACH’s Annex XIV serves to notify manufacturers and importers that they must apply for, and obtain, authorization for specific uses of these chemicals if they want to continue using them beyond their designated sunset dates in 2014 and 2015.  It is of note that this rule applies to the chemicals in question regardless of their production volumes.   Read More »

Posted in EU REACH, Health Policy | Also tagged , , , | Comments 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 EPA, Health Policy, Regulation | Also tagged , , , , , , , , | 1 Response, comments now closed

Not playing nice: The American Chemistry Council solidifies its claim to being the "industry of no"

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

If you had any doubt when reading my post earlier this week that the chemical industry isn't serious about real TSCA reform, watch American Chemistry Council (ACC) President and CEO Cal Dooley's hard-line performance at yesterday's hearing before a subcommittee of the House Energy and Commerce Committee (video link at the bottom of this page).  The legislative hearing focused on H.R. 5820, the Rush-Waxman Toxic Chemicals Safety Act of 2010 that was introduced last week.

All the themes I struck in my earlier blog post Mr. Dooley played out in spades:  more loud and long complaints aimed at every aspect of the bill; placing the worst possible interpretation on any provision subject to interpretation; playing the China and job-loss cards over and over; and last but not least, offering not a single constructive proposal of his own for reform.

A very different industry voice was also at the witness table, however – Howard Williams, V.P. & General Manager of the Pennsylvania division of Construction Specialties.  Mr. Williams deftly countered all of ACC's theatrics, embracing all of the bill's key provisions and making a strong business case for them.  Read More »

Posted in Health Policy, TSCA Reform | Also tagged , , , , , , | 1 Response, comments now closed

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 , , , , , , , , , , , | 5 Responses, comments now closed

A minimum data set: Who needs it?

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

Sound chemicals management and control demands sound information.  The Safer Chemicals Healthy Families coalition believes information sufficient to determine a chemical’s safety needs to be provided for all chemicals, as a condition for them to enter (for new chemicals) or remain (for existing chemicals) on the market.

Needed chemical information is not limited to test data, and even for types of data that can be derived from testing, alternative sources and approaches may be appropriately used.  Given the large number of chemicals for which information is needed, the availability of various sources of information, and the desirability of minimizing cost and use of laboratory animals, all reasonable efforts should be made to use existing information and data derived from the use of validated alternative methods – as long as the information they provide is current and scientifically reliable.

But who needs such information? Read More »

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

EPA deserves an “A for Effort” for its new Chemical Action Plans

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

Just squeaking in under its self-imposed deadline, late on December 30 EPA issued the first batch of chemical action plans it has promised under its enhanced chemical management program.  In doing so, EPA has signaled its intention to do all it can using its existing authority under the Toxic Substances Control Act (TSCA) – even as it also makes clear that authority is “both outdated and in need of reform.”  To my ear, that strikes just the right balance. Read More »

Posted in Health Policy, Regulation | Also tagged , , , , , , , , , | 1 Response, comments now closed

Let the games begin: Dueling TSCA reform manifestos

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

Today, the American Chemistry Council (ACC) unveiled its "10 Principles for Modernizing TSCA."  Also today, the Safer Chemicals, Healthy Families coalition – of which EDF is a member – issued a news release and unveiled its 9-point "Platform for Reform of TSCA."  How do they line up? Read More »

Posted in Health Policy, TSCA Reform | Also tagged , , , , , , , | 6 Responses, comments now closed
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