A minimum data set: Who needs it?

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

Sound chemicals management and control demands sound information.  The Safer Chemicals Healthy Families coalition believes information sufficient to determine a chemical’s safety needs to be provided for all chemicals, as a condition for them to enter (for new chemicals) or remain (for existing chemicals) on the market.

Needed chemical information is not limited to test data, and even for types of data that can be derived from testing, alternative sources and approaches may be appropriately used.  Given the large number of chemicals for which information is needed, the availability of various sources of information, and the desirability of minimizing cost and use of laboratory animals, all reasonable efforts should be made to use existing information and data derived from the use of validated alternative methods – as long as the information they provide is current and scientifically reliable.

But who needs such information?

Of course, EPA needs chemical data for several purposes:

  • to identify chemicals that meet – or don’t meet – specific criteria used to identify chemicals of concern; for example, to identify persistent, bioaccumulative and toxic (PBTs) chemicals;
  • to prioritize chemicals to determine the timing and sequence by which they should be subject to safety determinations; and
  • to actually conduct safety determinations.

We already know enough about many chemicals to identify them as chemicals of concern or otherwise prioritize them, so EPA does not need to wait for more data to start these processes.  As they are developed, however, such data can help to identify additional chemicals of concern or to refine prioritization decisions.

However, EPA is far from the only potential user of chemical information:

  • The market needs better data, to inform the myriad decisions made every day by companies and institutions that make, use, sell and buy chemicals and chemical products.
  • Downstream users in particular are demanding better data and evidence of safety.
  • State and local governments need data to inform their own chemical programs.
  • Consumers can use this information to inform their purchasing decisions.
  • Academic, industry and government scientists can use this information to guide their research.
  • Workers have a right to know about chemicals to which they may be exposed.
  • The general public has a right to know about chemicals to which they may be exposed.
  • Good information and access to it is a critical need for a transparent and accountable system of chemicals management.

The job of ensuring chemical safety is too big for EPA to do alone; only by enlisting all those who make chemical decisions and have a stake in them, and empowering them with good information, will the overall system deliver the protection we need.

I’ll have more to say in future posts about the nature, extent and types of chemical information all of these players need, and how TSCA can and should deliver it.

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