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

It’s got pictures of kids and families.  People of all colors.  Gentle hands cradling our fragile planet.  A hard hat resting on a pair of worn work gloves and a hammer.  It says the coalition is “people like you.”  It bears an uncanny resemblance to the website of the Safer Chemicals, Healthy Families campaign, of which EDF is a founding member.  But dig deeper and you’ll discover that the website of the “Coalition for Chemical Safety” is actually created and run by industry. Read more »

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  It reads:  “The Chemical Assessment and Management Program (ChAMP) has been superseded by the comprehensive approach to enhancing the Agency’s current chemicals management program announced by Administrator Lisa Jackson on September 29, 2009.”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:

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

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

Today, EPA Administrator Lisa Jackson unveiled the Obama Administration’s “Essential Principles for Reform of Chemicals Management Legislation.”  The principles’ significance lies not so much in the words they contain, but rather in what they symbolize:  A clear confirmation that this Administration understands that the Toxic Substances Control Act (TSCA) needs fundamental reform and that it is ready and willing to engage in making it happen. Read more »

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

In June, EPA published a Federal Register notice that included Significant New Use Rules (SNURs) for two carbon nanotubes (as well as 21 other chemicals).  That notice certainly got the attention of lawyers in town (see here, here and here).  The nanotube SNURs would require anyone planning to produce or process either of the two substances to notify EPA if the person intended not to comply with the (rather limited) risk management conditions specified by EPA.  Well, as reported yesterday by Sara Goodman of E&E News, EPA is now withdrawing the SNURs, at least temporarily.   

[Note:  Since first posting this Friday, I have made a few changes.  In first writing this post, I let show too much my frustration over the fact that even the smallest of steps taken by EPA to ensure some review of nanomaterials prior to their commercialization appears to have engendered an industry challenge.  In a few places, I got too personal and took some gratuitous swipes I shouldn't have.  I apologize for that, and have taken those out.] Read more »

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 »

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 »

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

In earlier posts (here and here), I discussed a notice EPA had received in July of 2008 from BASF reporting toxic effects at very low doses of a carbon nanotube (CNT) observed in a 90-day rat inhalation study.  In that notice, BASF had declared the specific identity of its CNT to be confidential business information, hence denying that information to the public.  Now, in a setting more to its liking, it appears the company has decided to reveal the identity after all. Read more »

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 »

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 »

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

Our analysis of EPA’s risk decision under ChAMP for this category of toxic chemicals vividly illustrates how EPA has failed to adopt a health-protective approach to its screening of HPV chemicals.  Rather, it misclassifies or understates these chemicals’ hazards, asserts that existing regulations are sufficient even when they are quite old or do not cover identified exposures, and naively assumes that children will not be as exposed as adults to consumer products used in the home unless they are intended for their use.  Finally, this case demonstrates that manufacturers are not reporting to EPA even readily available information on their chemicals’ uses.  Read more »