Chemicals & Nanomaterials

No orphan left behind: Health and environmental NGOs support EPA’s proposed paired rules to address high production volume "orphan" chemicals

By | Bio | Published: January 18, 2012

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

Environmental Defense Fund today submitted comments along with 15 other health, environmental justice and state and national environmental organizations, in support of EPA’s proposed rule to address the final batch of 45 “orphan” chemicals that were never sponsored under the agency’s earlier High Production Volume (HPV) Challenge Program. 

An earlier post to this blog highlighted and applauded the novel, innovative and efficient approach EPA has proposed, which actually entails the coupling of two rules:

(1) a test rule for 23 of these HPV chemicals for which EPA can make the requisite exposure findings to require testing, combined with:

(2) a Significant New Use Rule (SNUR) for the other 22 HPV chemicals for which EPA cannot presently make such findings, which requires companies to notify EPA if their production or use of those chemicals changes so as to increase the potential for exposure and then warrant testing.

The comments we filed today reiterate our strong support for this approach – and propose that the same approach be extended to several additional batches of HPV chemicals that still lack a basic set of hazard data.

Read More »

Posted in Data requirements, EPA, Exposure, Hazard, Inventory Update Rule, Policy, Regulation, Testing, TSCA | Comments closed

REACH starts to earn its "A": 20 chemicals headed to the Candidate List and 13 to Authorization

By | Published: December 21, 2011

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

The European Chemicals Agency (ECHA) has been busy this week implementing the EU's chemical regulation, REACH (short for Registration, Evaluation, Authorization and Restriction of Chemicals).

On Monday, ECHA announced it has added 20 more Substances of Very High Concern (SVHCs) to REACH's Candidate List.  These SVHCs are now eligible for later addition to Annex XIV, the list of SVHCs subject to Authorization.

Separately, the agency today forwarded its final recommendation that 13 chemicals already on the Candidate List be formally added to Annex XIV.  (We had blogged earlier about ECHA's initial recommendation proposing these 13 SVHCs for Authorization.)  If the European Commission confirms this addition, after a specified sunset date, the use of these will be allowed only if specifically authorized by EU authorities.  Read More »

Posted in Endocrine disruption, EPA, Hazard, Inventory Update Rule, REACH, TSCA | Comments closed

A new power couple: The combined impact of the microbiome and chemical exposures on disease susceptibility (Part 2 of 2)

By | Published: December 19, 2011

Allison Tracy is a Chemicals Policy Fellow. EDF Health Scientist Dr. Jennifer McPartland and Senior Scientist Dr. Richard Denison contributed to this post.

In Part 1 of this two-part post, I reviewed scientific evidence that the gut microbiome interacts with ingested chemicals to influence susceptibility to obesity and diabetes.  This hypothesis is the focus of a recent review article by Suzanne Snedeker and Anthony Hay.  Having reviewed evidence of the link between the microbiome and obesity and diabetes as well as the link between chemical exposures and obesity and diabetes, we now proceed to address this question:  Can the gut microbiome act in concert with ingested synthetic chemicals to predispose people to obesity and diabetes?

Read More »

Posted in Exposure, Health, Microbiome, Research | Comments closed

A new power couple: The combined impact of the microbiome and chemical exposures on disease susceptibility (Part 1 of 2)

By | Published: December 15, 2011

Allison Tracy is a Chemicals Policy Fellow.  EDF Health Scientist Dr. Jennifer McPartland and Senior Scientist Dr. Richard Denison contributed to this post.

When you’re standing at the kitchen counter this holiday season wrestling with the nebulous world of weight gain, think about synthetic chemicals.  A good number of them are in you.  And studies show that some of them are pretty busy in there, interacting with various biological systems – including your metabolism. 

But they’re not the only show in town.  Microbes are busy in your gut doing important things like digesting food and degrading harmful compounds.  But could they also influence the size of your love handles?  New science suggests that these microbes—in concert with certain chemicals—may have just this effect.

It is becoming increasingly clear that it’s not just your genes and your self control that determine your risk for obesity and related complications like diabetes.  Environmental factors are a big part of the equation, and those factors just might extend to synthetic chemicals to which you’re exposed, such as the flame retardants in your furniture and the plasticizers in food can linings.  Read More »

Posted in Bisphenol A, Exposure, Health, Microbiome, Research | Comments closed

Making do under TSCA: EPA to require reporting of health data by makers of chemicals used in hydraulic fracturing

By | Bio | Published: December 9, 2011

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

Last August, Earthjustice, Environmental Defense Fund (EDF) and over one hundred other groups recently filed a petition under the Toxic Substances Control Act (TSCA) calling on the Environmental Protection Agency (EPA) to require manufacturers and processors of chemicals used in oil and gas exploration and production (E&P chemicals) – including those used in hydraulic fracturing fluids – both to conduct testing and submit to EPA health and environmental data they already have on hand..  The aim of the petition was to ensure EPA obtains better information on the identity, production, use and health/environmental effects of these chemicals in order to evaluate their health and environmental risks.  Late last month, EPA announced its decision.  Read More »

Posted in EPA, Hazard, Industry, Regulation, Testing, TSCA | Comments closed

Twin dangers from TCE: Widespread exposure, and now a strong link to Parkinson disease

By | Bio | Published: November 22, 2011

Jennifer McPartland, Ph.D., is a Health Scientist.

A study published online in the Annals of Neurology last week, “Solvent Exposures and Parkinson Disease Risk in Twins,” adds to scientific evidence linking exposure to the solvent trichloroethylene, or TCE, and other common solvents with onset of Parkinson disease.  Parkinson disease is a debilitating condition well known for symptoms of trembling but can also include slowed motion, impaired posture and balance, and loss of automatic movements (e.g. blinking, arm swaying when walking).  Most unfortunately, it has no cure. 

According to the authors, this new twin study is the first confirmation in a population-based study of a significant association between exposure to TCE and incidence of Parkinson disease.    Read More »

Posted in EPA, Exposure, Hazard, Health, Regulation | Comments closed

EPA proposes yet another TSCA workaround: Creative, yes, but why not just give it the authority it needs?

By | Bio | Published: November 2, 2011

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

One thing I’ve learned in observing EPA try to operate under the Toxic Substances Control Act (TSCA) over the years is that – faced with limited authority and significant evidentiary and resource burdens – the Agency often has to resort to a workaround to get something it needs to do done.

Can’t ban a nasty chemical?  Wait until it’s voluntarily withdrawn and then pounce on it with a Significant New Use Rule (SNUR) to try to wedge the door closed.  Witness PFOS and penta and octaBDE.  (Under TSCA, without a SNUR in place on a chemical, a new producer or importer could start up without even letting EPA know; where EPA has issued a SNUR for a chemical, advance notification is required and EPA least has a chance to weigh in before production or import proceeds.)

Can’t require an up-front minimum data set for new chemicals?  Recommend to companies that for certain chemicals they submit such a data set along with the pre-manufacturing notice (PMN) they’re required to file, or risk having EPA extend the review of their new chemical or negotiate with them to do the testing.  EPA has made such “recommendations” for those relatively few new chemicals where the company “anticipates” at the outset producing it in large amounts in the first three years or where significant release or exposure is projected. 

The latest such workaround?  EPA’s simultaneous issuance of a proposed test rule and a proposed SNUR for a batch of high production volume (HPV) “orphan” chemicals that no company agreed to sponsor under the Agency’s voluntary HPV Challenge Program.

Necessity is the mother of invention, they say, and these creative new proposals are a case in point.  But, my oh my, there’s gotta be a better way…. Read More »

Posted in EPA, Exposure, Industry, Policy, Regulation, Testing, TSCA | Comments closed

New Ways in the Ancient World: Japan and China advance their chemicals policies

By | Published: October 5, 2011

Allison Tracy is a Chemicals Policy Fellow.

This isn’t the first time on this blog that we’ve observed that chemicals reform is popping up all over the world.  Whatever their strengths and shortcomings, the 1999 amendments to the Canadian Environmental Protection Act and the European Union’s REACH Regulation got the ball rolling.  The momentum of chemicals reform is reaching around the globe as governments pay more attention to the risks posed by chemicals.  In this post, we will focus on recent developments in Japan and China.

Japan and China are two of the U.S.’s top competitors, so it’s noteworthy that they have not allowed themselves to fall behind in chemicals management.  Why are they expanding their chemicals regulations?  Do they know something we don’t?  Read More »

Posted in Policy, REACH, Risk Assessment, TSCA | Comments closed

Expansion of my critique of the ACC tool's persistence and bioaccumulation criteria

By | Bio | Published: September 29, 2011

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

I want to clarify and expand on the discussion in my last post on ACC’s selection of criteria for persistence (P) and bioaccumulation (B).  The bottom line remains the same:  ACC selected the least conservative values proposed by any authoritative body for these parameters.  Read More »

Posted in Data requirements, EPA, Exposure, Hazard, Industry, REACH | Comments closed

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

By | Bio | Published: September 20, 2011

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 Data requirements, EPA, Exposure, Hazard, Industry, Policy, TSCA | Comments closed