Richard Denison, Ph.D., is a Senior Scientist.
In a post to this blog nearly a year ago, I noted that many voices in the chemical industry were claiming that EPA’s New Chemicals Program (NCP) was robust and served as an excellent model for TSCA reform. My post took considerable issue with that point of view, noting the many structural constraints TSCA imposes on EPA in its effort to review new chemicals:
- No data, no problem: No up-front testing requirement or minimum data set applies to new chemicals.
- Guessing game: EPA is forced to heavily rely on limited models and methods to predict the toxicity or behavior of a new chemical.
- Catch-22: While EPA can require testing of a new chemical on a case-by-case basis, it must first show the chemical may pose a risk – not an easy task without any data in the first place!
- One bite at the apple: EPA typically gets only a single opportunity to review a new chemical.
- Crystal-ball gazing: EPA has to try to anticipate a new chemical’s for-all-time future production and use.
- Black box: New chemical reviews lack transparency.
- Anti-precaution: In deciding whether to require testing or controls for a new chemical, EPA equates lack of evidence of harm with evidence of no harm.
Lately, I’ve been hearing chemical industry representatives trying to resuscitate the NCP-as-model-for-TSCA-reform mantra. So it is especially timely that a new report from EPA’s Office of Inspector General (OIG) has just been released that again thoroughly dismantles that notion. The new report’s critique of the NCP closely mirrors the appraisal I provided earlier. And adding weight to its analysis is the fact that EPA’s senior management has fully concurred with the report’s conclusions and recommendations. Read More