Selected tags: prioritization

ACC’s chemical prioritization tool: Helpful, but flawed and off the mark for EPA to use without TSCA reform

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

As I noted in my last post, the American Chemistry Council (ACC) issued its own “prioritization tool” in anticipation of the Environmental Protection Agency’s (EPA) public meetings  to get input on the approach it will use to identify additional chemicals of concern under its Enhanced Chemicals Management Program.

In the context of TSCA reform, various actors in the industry have long called for prioritization, often saying they support EPA’s ability to get off to a quick start on identifying chemicals for further work – only to propose schemes that are more likely to do the opposite.

ACC itself has over time come off as a bit schizophrenic on prioritization, apparently being for it before they were against it.  ACC’s release of its tool puts it squarely back in the pro-prioritization camp, but just what is it proposing?  My sense is it’s after something quite different from what EPA proposes, and frankly, different from what EPA is currently capable of deploying, given its limited authority and resources under TSCA.  In this sense, ACC’s proposal is more relevant in the context of TSCA reform, where we presumably would have an EPA with a mandate to review all chemicals in commerce, the authority to readily get the data it needs, and the resources required to execute the kind of comprehensive prioritization scheme ACC proposes.

But setting that disconnect aside for the moment, let’s delve a bit deeper into the ACC proposal on its own merits.  Read More »

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

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

A question of priorities: Comparing available statistics for baseball's "boys of summer" to those for U.S. chemical production and use

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

I’ve often been amazed when watching sports games on TV how quickly commentators can dig up the most obscure statistic about a player or team in real time, truly on the fly.  It’s not uncommon to be watching a game when a batter comes to the plate and I am immediately provided with his on-base percentage when batting left, facing that specific pitcher in the 9th inning when there’s a runner on second and his team is trailing by two or fewer runs.

I was reminded of all that this morning when perusing the New York Times sports page, which had this incredible graphic.  It depicts the exact location of every ball put in play this season by Yankee first baseman Mark Teixeira, who’s having a bad year, comparing how well (or in this case, poorly) he does when he bats left- vs. right-handed.

In the accompanying article, there is a link to Teixeira’s page showing batting stats for his entire career.  These include his batting stats for home vs. away games, games before vs. after the All-Star Game break, stats broken down by month of the season, by whether his team won or lost, by whether he was a starter or a substitute, by what position he was playing, by his position in the batting order, by inning, by what the ball-strike count was when he got a hit, by what bases were occupied at the time – this list represents only half of the slices and dices of the data provided on this one player’s page.

One player out of hundreds active this year, all with such stats available at the flick of a mouse.  Comparable stats on past players for decades past.  And this is just major league baseball.  There’s football, soccer, tennis, horse racing.

So, just one question:  Would somebody tell me why can’t I find out how many chemicals are produced in the U.S. and how they’re used?  Or what their hazards or risks are?

Speaking of the Toxic Substances Control Act (TSCA) and baseball, I can’t help but point to this recent quote (subscription required) that, believe it or not, links the two.  It was delivered by Fisk Johnson, CEO of S.C. Johnson & Son, at the American Chemical Society's 15th annual Green Chemistry & Engineering Conference in Washington, DC on June 21:

Your child has a better chance of becoming a Major League Baseball player than a chemical has of being regulated by EPA.

Now there’s a  statistic!

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

Funny name, serious concern: EPA proposes Significant New Use Rule for 14 glymes

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

EPA today proposed a Significant New Use Rule (SNUR) that, once finalized, would mandate that companies notify EPA prior to engaging in any “significant new use” of any of the 14 chemicals EPA has identified collectively as glymes.  Among other concerns, EPA has identified their use in various consumer products and their potential to cause reproductive and developmental toxicity.  For most of the glymes, the significant new use would be any use in a consumer product beyond those that are already ongoing.  For two of these chemicals, the significant new use would be any use.

This proposed SNUR, which was mired at the Office of Management and Budget (OMB) for more than six months, is now out for a 60-day public comment period.  A SNUR is essentially the only means available to EPA under the Toxic Substances Control Act (TSCA) by which it can try to limit the use of an existing chemical of concern.  It is far from a perfect means of doing so.

Nonetheless, within its limited authority under TSCA, today’s step by EPA brings at least some degree of scrutiny over a quite nasty group of chemicals.  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

A sea of red herrings is behind opposition to EPA’s proposal to enhance chemical reporting

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

With the chemical industry and now Congressional Republicans mounting a last-minute effort to derail the EPA’s long-time-in-coming enhancements to its Inventory Update Reporting (IUR) rule (see our last post), it’s worth examining their main objections.  That examination reveals a sea of red herrings.  Here are a few of the smelliest ones, discussed in detail in this post:

Red herring #1:  EPA has failed to indicate how it will use the information it collects.

Red herring #2:  Small businesses would be excessively burdened.

Red herring #3:  More frequent reporting is a “needless” burden on the industry.

Red herring #4:  EPA is expanding the IUR from data reporting to data-gathering.

Red herring #5:  EPA’s requirement for retroactive reporting is unfair.

Red herring #6:  Requiring electronic reporting is too inflexible.

Read More »

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

House leadership asks White House to scrap IUR enhancements: Where are ACC’s principles now?

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

[Update:  Here are links to the Chairmen's news release and letter to OMB.]

E&E News is reporting (subscription required) that House Energy & Commerce Committee Chairman Fred Upton has called on the White House to scrap the Environmental Protection Agency’s (EPA) soon-to-be-issued enhancements to the only routine reporting system for chemicals across the entire federal government.

The final EPA rule would expand EPA’s Inventory Update Reporting (IUR), which requires periodic reporting of chemicals subject to the Toxic Substances Control Act (TSCA).  The rule was sent to the Office of Management and Budget (OMB) on January 20 and is awaiting approval.

Chairman Upton’s move, in the form of a letter to OMB Director Jacob Lew cosigned by Environment and Economy Subcommittee Chairman John Shimkus, follows closely on the chemical industry’s loud complaints about the rule late last month at the GlobalChem conference, cosponsored by the American Chemistry Council (ACC) and the Society of Chemical Manufacturers and Affiliates (SOCMA).  What gives?  Read More »

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

Memo to ACC et al.: What’s said in Maryland doesn’t stay in Maryland

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

It’s only a little more than 30 miles from Washington, DC to Annapolis, the Capitol of the State of Maryland.  But to judge from testimony given there on February 24 and March 1 by representatives of the chemical, formulated products and food industries, you’d think Annapolis existed in a parallel universe, with only a passing resemblance to the one in DC.

The occasions were hearings on companion bills introduced into the Maryland State Senate, SB 637, and the State House of Delegates, HB 759, titled the “Healthy Kids, Healthy Maryland – Toxic Chemical Identification and Reduction.”

Actually, the industry associations’ testimonies suggest either of two alternative universes.  In one of them, Maryland should do nothing to address dangerous chemical exposures because the federal Toxic Substances Control Act (TSCA) and other related laws are working quite well, thank you very much.  Residing in this parallel universe are the American Chemistry Council (ACC), the American Cleaning Institute (ACI, until recently the more accurately named Soap and Detergent Association), the Maryland Industrial Technology Alliance and the Consumer Specialty Products Association (CSPA).

In the other parallel universe, Maryland should do nothing to address dangerous chemical exposures because it will only get in the way of TSCA reform, which is just around the corner.  Inhabiting this alternative universe are the Grocery Manufacturers Association (GMA), the Can Manufacturers Institute, and yes – as another indication that it just can’t quite make up its mind about TSCA reform – once again, the American Chemistry Council.  Read More »

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

Why is OMB blocking EPA from using even its limited authority under TSCA?

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

On May 12 of this year, the Environmental Protection Agency (EPA) sent a proposed rule to the Office of Management and Budget’s (OMB’s) Office of Information and Regulatory Affairs (OIRA) for its review, which is supposed to be completed within 90 days.  The proposed rule is not considered a major rule, is classified as “not economically significant,” imposes no unfunded mandates and is unequivocally allowed under EPA’s statutory authority under the Toxic Substances Control Act (TSCA).

The proposed rule would establish a so-called “chemicals of concern” list and populate it with one chemical and two chemical categories.  All of these chemicals are well-studied, already widely identified to be chemicals of significant concern and subject to numerous regulations by governmental bodies both in the U.S. and abroad.

Yet, as of today – more than seven months after receiving the draft of the proposed rule from EPA – OMB has not allowed EPA to release it for public notice and comment.

In 1976, when passing TSCA, Congress gave EPA the express authority to establish and populate a “chemicals of concern” list.  There’s simply no excuse for OMB’s delay.  Read More »

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

Adding a hammer to TSCA's tool belt: Clear deadlines and, yes, hammers to ensure they’re met, are essential to TSCA reform

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

For decades, the American chemical industry has produced and used chemicals virtually without condition, due to the laissez-faire approach embodied in TSCA.  The consequence?  Tens of thousands of chemicals are in everyday use with little health and environmental data, let alone evidence of their safety.  This has led to a crisis in confidence among commercial buyers, users and sellers of chemicals and products made using chemicals – not to mention consumers, state and local government and the general public.

Meaningful TSCA reform must address these problems, by not only systematically subjecting chemicals on the market to data requirements and safety determinations – but also ensuring all this is done in an efficient and timely manner.

That’s where hammers come in.  Read More »

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