Category Archives: ChAMP

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

By | Bio | Published: July 11, 2011

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 »

Also posted in Consumer Products, EPA, Exposure, Hazard, Health, Inventory Update Rule, Regulation, TSCA, Worker Safety | Comments closed

How to turn a "quick start" into a choke point

By | Bio | Published: November 18, 2009

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

Over the last few months, I was heartened to hear a number of industry stakeholders in the debate over TSCA reform embrace the idea of designating in TSCA reform legislation a "jump-start" or "quick-start" list of chemicals of high concern or priority.  The idea was to allow EPA to hit the ground running, by having an agreed-to list of chemicals on which it could immediately initiate action.  Well, it now appears many in industry actually have something far slower and far more cumbersome in mind. Read More »

Also posted in California, EPA, Industry, Regulation, Risk Management, TSCA | Comments closed

Over-Exposed: Why relying on exposure to prioritize chemicals is dangerous

By | Bio | Published: November 11, 2009

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

When the chemical industry talks about prioritization – a central question in the debate over TSCA reform – more often than not it quickly reduces the question down to the argument that we should focus only on those chemicals, however hazardous or untested they may be, to which we know people are exposed.  In a perfect world, that might suffice.  But, as this post will explore, the world of exposure assessment is anything but perfect.  Read More »

Also posted in Canada, EPA, Exposure, Hazard, Industry, Policy, REACH, Risk Assessment, TSCA | Comments closed

ChAMP "superseded": EPA shifts into action mode

By | Bio | Published: October 1, 2009

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 »

Also posted in EPA, Industry, Policy, Regulation, Testing, TSCA | Comments closed

EPA announcement on ChAMP

By | Bio | Published: June 19, 2009

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

It probably goes without saying that EDF welcomes EPA's decision to suspend the development and posting of risk-based prioritizations under its Chemical Assessment and Mangement Program (ChAMP).  EDF has been arguing (see our earlier posts) that ChAMP's "rush to risk" has taken EPA badly off-track.  But we have also identified many useful things that EPA's existing chemicals program can and should be doing with the data it obtained through the HPV Challenge (whether called ChAMP or not) .

We look forward to working with EPA to craft a new approach, grounded in a return to developing scientifically defensible hazard, not risk, characterizations and transparently identifying and addressing data gaps and data quality problems.

Also posted in EPA | Comments closed

Using ChAMP to Advance Alternative Testing Technologies

By | Bio | Published: June 16, 2009

Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

Many of the screening-level hazard data being collected and analyzed under ChAMP that pertain to human health are derived from traditional laboratory animal studies.  The National Academy of Sciences (NAS) recently offered a "new paradigm for toxicity testing" in its 2008 report Toxicity Testing in the 21st Century: a Vision and a Strategy.  Can ChAMP hazard data be used to facilitate the development of new testing strategies?  Read More »

Also posted in EPA, In Vitro, NAS, Testing | Comments closed

ChAMP's double standard

By | Bio | Published: June 1, 2009

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 »

Also posted in EPA, Policy, Regulation, Risk Assessment, Risk Management, Testing | Comments closed

Greening ChAMP

By | Bio | Published: May 27, 2009

Cal Baier-AndersonCal Baier-Anderson, Ph.D., is a Health Scientist.

In our critique of EPA's Chemical Assessment and Management Program (ChAMP), we have pointed out that, despite its limitations, there is value in the hazard data that EPA is collecting and analyzing.  How so? Read More »

Also posted in Consumer Products, EPA, Policy | Comments closed

(How) Can ChAMP get back on track?

By | Bio | Published: May 7, 2009

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

As I noted in our first post on ChAMP, after getting off to a strong start in 2007, EPA's abrupt decision in 2008 to steer ChAMP in the direction of cranking out hasty risk decisions was entirely its own.  Can ChAMP be put back on track?  Read More »

Also posted in EPA, Policy, Risk Assessment, Risk Management, TSCA, Worker Safety | Comments closed

Questionable Risk Decisions under ChAMP: The Fatty Nitrogen Derived Cationics Category

By | Bio | Published: May 1, 2009

Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

This example raises some new issues as well as some we discussed in the earlier examples:  EPA relies on a highly flawed "category approach" that ignores major differences in the properties and structures of the 13 members of this category.  It compounds this problem by unquestioningly accepting data from inadequate studies to assert low toxicity, rather than demanding that sufficient studies be provided.  As a result, it fails to identify, let alone require to be filled, the enormous gaps in the data available for many of the category members.  EPA ignores or dismisses without explanation its own earlier comments raising serious concerns about the quality and completeness of data provided by the sponsor of these chemicals under the HPV Challenge.  Finally, this example once again shows how EPA's heavy reliance on self-reported use information from manufacturers paints an incomplete and potentially very misleading picture of the actual uses of industrial chemicals.  Read More »

Also posted in Consumer Products, EPA, Policy, Regulation, Risk Assessment, TSCA | Comments closed