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	<title>Comments for Chemicals &amp; Nanomaterials</title>
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	<link>http://blogs.edf.org/nanotechnology</link>
	<description>Our experts&#039; views on chemical and nano news</description>
	<lastBuildDate>Tue, 11 Jun 2013 07:09:33 +0000</lastBuildDate>
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		<title>Comment on Reality check on TSCA reform legislation by howtoshortpromdressf</title>
		<link>http://blogs.edf.org/nanotechnology/2013/06/05/reality-check-on-tsca-reform-legislation/comment-page-1/</link>
		<dc:creator>howtoshortpromdressf</dc:creator>
		<pubDate>Tue, 11 Jun 2013 07:09:33 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2745#comment-5945</guid>
		<description>Hello! I simply would like to give a huge thumbs up for the nice information you will have right here on this post. I might be coming again to your weblog for extra soon. how to short prom dress for prom night http://cavewave42.xanga.com/772076203/an-attractive-bridal-underwear-bathe-notion/</description>
		<content:encoded><![CDATA[<p>Hello! I simply would like to give a huge thumbs up for the nice information you will have right here on this post. I might be coming again to your weblog for extra soon. how to short prom dress for prom night <a href="http://cavewave42.xanga.com/772076203/an-attractive-bridal-underwear-bathe-notion/" rel="nofollow">http://cavewave42.xanga.com/772076203/an-attractive-bridal-underwear-bathe-notion/</a></p>
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		<title>Comment on Reality check on TSCA reform legislation by John</title>
		<link>http://blogs.edf.org/nanotechnology/2013/06/05/reality-check-on-tsca-reform-legislation/comment-page-1/</link>
		<dc:creator>John</dc:creator>
		<pubDate>Fri, 07 Jun 2013 01:26:03 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2745#comment-5931</guid>
		<description>Richard,

Let me start by first saying, I greatly appreciate and respect your leadership on this issue.   However I am troubled by your characterization of those who oppose this legislation.  There are many thoughtful people, myself included, who think this proposal is a mistake and will do little to fix our troubled chemical management system.  While I can only speak for myself, I am not opposed to compromise and think that there is a reasonable middle ground that could be found, but this is not it.  I also think that thoughtful considerate people can reject your basic premises regarding the benefits of this proposal.  

You say that this law will mandate a review of all chemicals in commerce, which it does.  But with the amount of work that EPA needs to do to first conduct safety assessment, order testing, make safety determinations, and then adopt rules.  Even if EPA is able to do 100 safety determinations a year, which I think is optimistic given what’s required of them, it will take 620 years to evaluate all chemicals in commerce for safety.  Hell, if they can do 1000 a year, it will still take 62 years.

You say the risk standard is different.  I don’t think the courts will see it that way.  Amassing “substantial evidence” of an “unreasonable risk” sounds like a tall order to me.

Your final point I agree, EPA can now use orders to get data.  However for this, states are preempted and we lose a once in a generation opportunity to make real change to how our country regulates chemicals.</description>
		<content:encoded><![CDATA[<p>Richard,</p>
<p>Let me start by first saying, I greatly appreciate and respect your leadership on this issue.   However I am troubled by your characterization of those who oppose this legislation.  There are many thoughtful people, myself included, who think this proposal is a mistake and will do little to fix our troubled chemical management system.  While I can only speak for myself, I am not opposed to compromise and think that there is a reasonable middle ground that could be found, but this is not it.  I also think that thoughtful considerate people can reject your basic premises regarding the benefits of this proposal.  </p>
<p>You say that this law will mandate a review of all chemicals in commerce, which it does.  But with the amount of work that EPA needs to do to first conduct safety assessment, order testing, make safety determinations, and then adopt rules.  Even if EPA is able to do 100 safety determinations a year, which I think is optimistic given what’s required of them, it will take 620 years to evaluate all chemicals in commerce for safety.  Hell, if they can do 1000 a year, it will still take 62 years.</p>
<p>You say the risk standard is different.  I don’t think the courts will see it that way.  Amassing “substantial evidence” of an “unreasonable risk” sounds like a tall order to me.</p>
<p>Your final point I agree, EPA can now use orders to get data.  However for this, states are preempted and we lose a once in a generation opportunity to make real change to how our country regulates chemicals.</p>
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		<title>Comment on My mother is not Angelina Jolie by Rachel</title>
		<link>http://blogs.edf.org/nanotechnology/2013/05/21/my-mother-is-not-angelina-jolie/comment-page-1/</link>
		<dc:creator>Rachel</dc:creator>
		<pubDate>Wed, 22 May 2013 19:30:51 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2729#comment-5878</guid>
		<description>Thanks Mike, I appreciate your comment. And I’m very sorry to hear about your mother. 
I have theories about my mom&#039;s cancer as well, and I share your frustration that its hard to pin down a specific cause. I do hope that Jolie’s action will increase awareness and prompt further discussion about breast cancer in this country.</description>
		<content:encoded><![CDATA[<p>Thanks Mike, I appreciate your comment. And I’m very sorry to hear about your mother.<br />
I have theories about my mom&#039;s cancer as well, and I share your frustration that its hard to pin down a specific cause. I do hope that Jolie’s action will increase awareness and prompt further discussion about breast cancer in this country.</p>
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		<title>Comment on My mother is not Angelina Jolie by Mike Wilson</title>
		<link>http://blogs.edf.org/nanotechnology/2013/05/21/my-mother-is-not-angelina-jolie/comment-page-1/</link>
		<dc:creator>Mike Wilson</dc:creator>
		<pubDate>Tue, 21 May 2013 14:06:46 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2729#comment-5871</guid>
		<description>Well done, thank you Rachel. My mother died of breast cancer in 1999 at age 64 and was the first member of her family to develop the disease, ever. I&#039;ve always thought that there might be link to the hair spray she used every day for years and years that used a chlorinated solvent as the primary base product. Easy to cast doubt though, of course.
best,
Mike</description>
		<content:encoded><![CDATA[<p>Well done, thank you Rachel. My mother died of breast cancer in 1999 at age 64 and was the first member of her family to develop the disease, ever. I&#039;ve always thought that there might be link to the hair spray she used every day for years and years that used a chlorinated solvent as the primary base product. Easy to cast doubt though, of course.<br />
best,<br />
Mike</p>
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		<title>Comment on Variety is the spice of … accurate chemical testing by Rachel Shaffer</title>
		<link>http://blogs.edf.org/nanotechnology/2013/01/10/variety-is-the-spice-of-accurate-chemical-testing/comment-page-1/</link>
		<dc:creator>Rachel Shaffer</dc:creator>
		<pubDate>Fri, 11 Jan 2013 20:58:43 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2513#comment-4979</guid>
		<description>Thank you very much for your comment, Andrew.  New testing methods certainly offer the opportunity to advance our understanding of how chemicals can affect our health, while also potentially reducing costs and the need for laboratory animals.  However, they present challenges as well that will take time and effort to overcome.  We couldn&#039;t agree more that collaborative efforts are needed to facilitate effective and appropriate development and use of these new methods.</description>
		<content:encoded><![CDATA[<p>Thank you very much for your comment, Andrew.  New testing methods certainly offer the opportunity to advance our understanding of how chemicals can affect our health, while also potentially reducing costs and the need for laboratory animals.  However, they present challenges as well that will take time and effort to overcome.  We couldn&#039;t agree more that collaborative efforts are needed to facilitate effective and appropriate development and use of these new methods.</p>
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		<title>Comment on Variety is the spice of … accurate chemical testing by Andrew Rowan</title>
		<link>http://blogs.edf.org/nanotechnology/2013/01/10/variety-is-the-spice-of-accurate-chemical-testing/comment-page-1/</link>
		<dc:creator>Andrew Rowan</dc:creator>
		<pubDate>Thu, 10 Jan 2013 20:59:33 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2513#comment-4956</guid>
		<description>The above posting illustrates the advantage that new hi-thruput approaches offer to chemical risk assessment.  These new hi-thruput techniques allow one to generate data at least a million times faster (according to my crude, &quot;back-of-the-envelope&quot; calculations) than the traditional animal testing approaches.  As a result of this, the new approaches open up tremendous opportunities for new bioinformatic analyses of this flood of new data, leading to a rapid expansion of both understanding of toxicity pathways and the potential risks to humans and the environment.   We now need a more co-ordinated approach to take advantage of these new approaches (and understanding?) and identify how we should spend the approximate $200+ million a year that is currently being devoted globally to developing and implementing new testing strategies and risk assessment systems in the most effective way.</description>
		<content:encoded><![CDATA[<p>The above posting illustrates the advantage that new hi-thruput approaches offer to chemical risk assessment.  These new hi-thruput techniques allow one to generate data at least a million times faster (according to my crude, &#034;back-of-the-envelope&#034; calculations) than the traditional animal testing approaches.  As a result of this, the new approaches open up tremendous opportunities for new bioinformatic analyses of this flood of new data, leading to a rapid expansion of both understanding of toxicity pathways and the potential risks to humans and the environment.   We now need a more co-ordinated approach to take advantage of these new approaches (and understanding?) and identify how we should spend the approximate $200+ million a year that is currently being devoted globally to developing and implementing new testing strategies and risk assessment systems in the most effective way.</p>
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		<title>Comment on Chemicals R Us: New ACC-sponsored website says chemicals are safe and fun for kids! by Michael Dourson</title>
		<link>http://blogs.edf.org/nanotechnology/2012/12/19/chemicals-r-us-new-acc-sponsored-website-says-chemicals-are-safe-and-fun-for-kids/comment-page-1/</link>
		<dc:creator>Michael Dourson</dc:creator>
		<pubDate>Thu, 20 Dec 2012 23:18:04 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2493#comment-4804</guid>
		<description>Thank you for taking an interest in our website (http://www.kidschemicalsafety.org/).  We welcome all thoughtful, valid, and constructive comments.  Perhaps more importantly, we continue to invite questions from parents, grandparents, teachers, etc. on chemicals of interest to them.  Since no sponsor dictates our content, subject matter, or message, anyone interested can feel free to ask questions, and we will strive to write essays in response that are balanced, accurate, to the point, and timely.  Holiday Cheers!  

Michael Dourson, Toxicology Excellence for Risk Assessment</description>
		<content:encoded><![CDATA[<p>Thank you for taking an interest in our website (<a href="http://www.kidschemicalsafety.org/" rel="nofollow">http://www.kidschemicalsafety.org/</a>).  We welcome all thoughtful, valid, and constructive comments.  Perhaps more importantly, we continue to invite questions from parents, grandparents, teachers, etc. on chemicals of interest to them.  Since no sponsor dictates our content, subject matter, or message, anyone interested can feel free to ask questions, and we will strive to write essays in response that are balanced, accurate, to the point, and timely.  Holiday Cheers!  </p>
<p>Michael Dourson, Toxicology Excellence for Risk Assessment</p>
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		<title>Comment on Chemicals R Us: New ACC-sponsored website says chemicals are safe and fun for kids! by Michael Jayjock</title>
		<link>http://blogs.edf.org/nanotechnology/2012/12/19/chemicals-r-us-new-acc-sponsored-website-says-chemicals-are-safe-and-fun-for-kids/comment-page-1/</link>
		<dc:creator>Michael Jayjock</dc:creator>
		<pubDate>Thu, 20 Dec 2012 00:10:18 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2493#comment-4725</guid>
		<description>I find calling TERA the ACC’s “right-hand” and putting “non-profit” in quotes to be an unwarranted cheap shot and low blow.   Indeed,  I have worked with TERA for many years and see them to be one of the most objective and above- board organizations of its kind.    Mike Dourson’s vision and implementation as the founder and leader of TERA has, in my opinion, been simply impeccable as a bastion of scientific integrity.
 
I typically appreciate and agree with Richard Denison’s writing and point of view but he has clearly and badly missed the mark here.   He should not see a positive and moderate stance on these issues as an affront to any claim he might have to the moral high ground.    I found this particular piece to be somewhat righteous and self-serving.</description>
		<content:encoded><![CDATA[<p>I find calling TERA the ACC’s “right-hand” and putting “non-profit” in quotes to be an unwarranted cheap shot and low blow.   Indeed,  I have worked with TERA for many years and see them to be one of the most objective and above- board organizations of its kind.    Mike Dourson’s vision and implementation as the founder and leader of TERA has, in my opinion, been simply impeccable as a bastion of scientific integrity.</p>
<p>I typically appreciate and agree with Richard Denison’s writing and point of view but he has clearly and badly missed the mark here.   He should not see a positive and moderate stance on these issues as an affront to any claim he might have to the moral high ground.    I found this particular piece to be somewhat righteous and self-serving.</p>
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		<title>Comment on EDF comments at EPA&#039;s public stakeholder meeting on its IRIS Program by Perry Cohn</title>
		<link>http://blogs.edf.org/nanotechnology/2012/11/14/edf-comments-at-epas-public-stakeholder-meeting-on-its-iris-program/comment-page-1/</link>
		<dc:creator>Perry Cohn</dc:creator>
		<pubDate>Sat, 17 Nov 2012 03:12:59 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2453#comment-4531</guid>
		<description>Very accurate description.  My viewpoint also.</description>
		<content:encoded><![CDATA[<p>Very accurate description.  My viewpoint also.</p>
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		<title>Comment on Still looking for a moment of truth from ACC by Jon</title>
		<link>http://blogs.edf.org/nanotechnology/2012/09/11/still-looking-for-a-moment-of-truth-from-acc/comment-page-1/</link>
		<dc:creator>Jon</dc:creator>
		<pubDate>Wed, 12 Sep 2012 14:43:15 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.edf.org/nanotechnology/?p=2409#comment-4408</guid>
		<description>At the New York State hearing on flame retardant chemicals in children&#039;s products on September 6th, Jackson Morrill of the ACC&#039;s NAFRA stated that EPA, under its New Chemicals Program, has blocked a number of chemicals from entering the market place but was not sure how many. Any idea where I can find out how many new chemicals agency has blocked?</description>
		<content:encoded><![CDATA[<p>At the New York State hearing on flame retardant chemicals in children&#039;s products on September 6th, Jackson Morrill of the ACC&#039;s NAFRA stated that EPA, under its New Chemicals Program, has blocked a number of chemicals from entering the market place but was not sure how many. Any idea where I can find out how many new chemicals agency has blocked?</p>
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