Tag Archives: prioritization

Why can’t ACC tell the truth about the Safe Chemicals Act?

By Richard Denison | Bio | Published: May 6, 2013

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

It’s very disheartening to see just how far the American Chemistry Council (ACC) has moved away from anything resembling a good-faith effort to debate and advance meaningful reform of the Toxic Substances Control Act (TSCA). There’s more than enough in TSCA reform for stakeholders to debate and disagree about without adding distortions and outright falsehoods to the mix, yet ACC seems intent on doing just that.

The latest indication? An April 16, 2013 post to ACC’s blog titled “A new year, but the same unworkable Safe Chemicals Act.” The post purports to identify four fatal flaws in the Safe Chemicals Act of 2013, which was introduced on April 10 and is cosponsored by 29 Senators. The first two utterly ignore or fault the legislation for major changes made to it to address industry concerns, while the latter two once again restate outright falsehoods ACC has made about the Act – claims that ACC knows are false. Read More »

Posted in Health Policy, TSCA | Also tagged aggregate exposure, American Chemistry Council (ACC), children's safety, Confidential Business Information (CBI), exposure and hazard, industry tactics, risk assessment, Safe Chemicals Act | 1 Response

Variety is the spice of … accurate chemical testing

By Rachel Shaffer | Published: January 10, 2013

Rachel Shaffer is a research assistant. Jennifer McPartland, Ph.D., is a Health Scientist.

There has been a lot of buzz in recent years about the federal government’s new chemical testing initiatives, ToxCast and Tox21 (see, for example, these articles in Scientific American and the New York Times). These programs are developing high-throughput (HT) in-vitro testing to evaluate—and ultimately predict—the biological effects of chemicals. In contrast to the relatively slow pace of traditional animal testing, ToxCast and Tox21 use sophisticated robots to rapidly test thousands of chemicals at a time. As a result, they hold the potential to more efficiently fill enormous gaps in available health data, predict adverse effects, and shed light on exactly how chemicals interact and interfere with our biology. (For more on these potential benefits, see Section 5 of EDF’s Chemical Testing Primer).

Yet, among the key challenges that these new methods must address is one that traditional, animal-based methods have faced for decades: how can laboratory testing adequately account for the high degree of variability in the human population? The latest research suggests the exciting possibility that genetic diversity, at least, may be able to be incorporated into emerging HT in vitro approaches. Read More »

Posted in Health Science | Also tagged computational toxicology, in vitro, risk assessment, vulnerable populations | Comments closed

Despite TSCA-like law, there is movement down under on chemical safety

By Alissa Sasso | Published: October 2, 2012

Alissa Sasso is a Chemicals Policy Fellow.

Australia’s chemical law, dating back to 1989, in many ways resembles the U.S. Toxic Substances Control Act of 1976 (TSCA). Australia, however, has begun taking steps to address tens of thousands of existing chemicals at a scale that has not been taken in the U.S. These steps come in the wake of government and stakeholder recognition that Australia’s TSCA-like approach to chemicals management is inadequate and in need of revision. Read More »

Posted in Health Policy, TSCA | Also tagged Australia, risk assessment, Substances of Very High Concern (SVHC) | Comments closed

Repost: The new Safe Chemicals Act fulfills every detail of ACC’s 10 “Principles for Modernizing TSCA”

By Richard Denison | Bio | Published: September 6, 2012

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

[NOTE: I am reposting this piece, given that it was first posted during the dog days of August and I don't want those interested to have missed it in digging out from time away from the office. If you have an interest in understanding just how much the Safe Chemicals Act has changed to account for earlier industry concerns, please take the time to look at the analysis I've done comparing the bill to ACC's TSCA Principles.]

You wouldn’t know it from listening to the American Chemistry Council (ACC) talk about the Safe Chemicals Act, but the new and improved version of the bill that was passed out of the Senate Environment & Public Works Committee on July 25 closely mirrors every detail of ACC’s 10 “Principles for Modernizing TSCA.”.

Those principles, issued in August of 2009, represent a key reference point given that they are virtually the only somewhat detailed public articulation by ACC of its substantive position on TSCA reform, one to which ACC continues to refer today. In describing its principles, ACC says they “create a roadmap to a modern chemical regulatory system that will protect public health and the environment, while preserving the ability of American chemical companies to drive innovation, grow jobs, and compete in the global marketplace.”

ACC indicated in its statement on the revised bill that it only conducted a “cursory review” of the bill language, which perhaps explains why it got even some basics wrong. One example: ACC claims “[t]he bill would also dramatically increase the time it would take for the Environmental Protection Agency (EPA) to review new chemicals.” In fact, the revised bill retains the 90-day review period for new chemicals operable under current TSCA.

So how does the bill stack up against ACC’s 10 Principles for TSCA Modernization? Read More »

Posted in Health Policy, TSCA | Also tagged American Chemistry Council (ACC), Confidential Business Information (CBI), data requirements, risk assessment, Safe Chemicals Act | Comments closed

Onwards and upwards: South Korea and Turkey advance their REACH-like policies

By Alissa Sasso | Published: August 22, 2012

Alissa Sasso is a Chemicals Policy Fellow. Richard Denison, Ph.D., is a Senior Scientist.

This summer we saw a flurry of activity surrounding our own chemical safety legislation, the Toxic Substances Control Act (TSCA); international reform efforts have been just as busy. In this blog post, we’ll discuss recent developments in toxic chemicals management in South Korea and Turkey. As apparent in our recent post on new Chinese regulations, these developments are notable because of their alignment with the EU’s REACH legislation. Read More »

Posted in Health Policy, TSCA and REACH | Also tagged South Korea, Substances of Very High Concern (SVHC), Turkey | Comments closed

The new Safe Chemicals Act fulfills every detail of ACC’s 10 “Principles for Modernizing TSCA”

By Richard Denison | Bio | Published: August 20, 2012

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

So how does the bill stack up against ACC’s 10 Principles for TSCA Modernization? Read More »

Posted in Health Policy, TSCA | Also tagged American Chemistry Council (ACC), Confidential Business Information (CBI), data requirements, risk assessment, Safe Chemicals Act | Comments closed

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

By Richard Denison | 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 Health Policy, TSCA | Also tagged American Chemistry Council (ACC), biomonitoring, Canada, consumer products, data requirements, exposure and hazard, Globally Harmonized System (GHS) | Comments closed

Avoiding paralysis by analysis: EPA proposes a sensible approach to identifying chemicals of concern

By Richard Denison | Bio | Published: September 13, 2011

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 Health Policy, TSCA | Also tagged American Chemistry Council (ACC), biomonitoring, Canada, Chemical Assessment and Management Program (ChAMP), chemical identity, exposure and hazard, Globally Harmonized System (GHS), in vivo, IUR/CDR, Persistent Bioaccumulative and Toxic (PBT), prenatal, Safer Chemicals Healthy Families, test rule, worker safety | Comments closed

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

By Richard Denison | Bio | Published: August 8, 2011

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 9^th 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 BaseballReference.com 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, TSCA | Tagged prioritization | Comments closed

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

By Richard Denison | 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 »

Posted in Health Policy, TSCA | Also tagged Chemical Assessment and Management Program (ChAMP), consumer products, High Production Volume (HPV), IUR/CDR, Office of Management and Budget (OMB), Significant New Use Rule (SNUR) | Comments closed

Chemicals & Nanomaterials

Tag Archives: prioritization

Why can’t ACC tell the truth about the Safe Chemicals Act?

Variety is the spice of … accurate chemical testing

Despite TSCA-like law, there is movement down under on chemical safety

Repost: The new Safe Chemicals Act fulfills every detail of ACC’s 10 “Principles for Modernizing TSCA”

Onwards and upwards: South Korea and Turkey advance their REACH-like policies

The new Safe Chemicals Act fulfills every detail of ACC’s 10 “Principles for Modernizing TSCA”

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

Avoiding paralysis by analysis: EPA proposes a sensible approach to identifying chemicals of concern

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

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

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