Richard Denison, Ph.D., is a Senior Scientist.
I want to clarify and expand on the discussion in my last post on ACC’s selection of criteria for persistence (P) and bioaccumulation (B). The bottom line remains the same: ACC selected the least conservative values proposed by any authoritative body for these parameters. Read More
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
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