EDF Health

State-level nano regulation: Yes, indeed, the industry “should have seen it coming” – it caused it!

By / Published: September 10, 2010

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

I just read an interesting column by John DiLoreto, CEO of NanoReg, that appears online at Nanotechnology Now.  It’s titled “We Should Have Seen It Coming: States Regulating Nanotechnology.”  It nicely describes the important role states play in advancing environmental policy and regulation – especially when the feds are asleep at the wheel.  And it also gives a neat rundown of the various state actions aimed at nanomaterials that are underway.

But, search as I might, I couldn’t find a single acknowledgment in Mr. DiLoreto’s latest column – or in his earlier related column titled “What Drives the Regulation of Nanomaterials?” – of the role the nanotechnology industry itself played in bringing all of this on itself.

That’s quite an omission, in my view, given that the industry’s actions (or, more accurately, the lack thereof) played a central role in getting us to where we are (or, more accurately, aren’t) today on nanotechnology oversight.  That includes driving states to feel they had to step in to fill the federal void.   Read More »

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Affirming a thing of beauty: Comments filed today support new EPA CBI policy

By / Published: August 25, 2010

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

Today EDF joined with Earthjustice and 24 other health, labor and environmental organizations in filing comments with EPA that support its recently announced policy change restoring the public’s right to know the identities of all chemicals for which health and safety data have been submitted to the agency.

I have already done a post on the details of EPA’s new policy, which I termed “a thing of beauty.”  The comments we filed today – in response to EPA’s request when it issued its new policy back in May – make clear that the policy reflects both the clear meaning of the Toxic Substances Control Act (TSCA) and the clear intent of its drafters.   Read More »

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EPA seeks to improve TSCA data reporting; a real litmus test looms for the chemical industry

By / Published: August 20, 2010

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

While I was on vacation last week, EPA’s proposed rule to improve chemical information reporting under its so-called Inventory Update Rule (IUR) was finally published in the Federal Register.  (I say “finally” because the proposal languished for almost 6 months over at OMB, nearly double the 90 days such mandatory reviews are supposed to take.  That unfortunate delay is curious given the relatively modest changes that appear to have been made by OMB – mostly limited to compelling EPA to shift a few elements from proposals to options open to comment, and requiring EPA to expand the range of issues on which it now seeks comment.)

I won’t summarize the EPA proposals here; EPA’s factsheet does a good job of that, and Daniel Rosenberg at NRDC has also nicely recapped the proposal on his blog.  Suffice it to say that the proposed changes would go far to address the many failings of the current IUR, which amply manifested themselves in the last reporting cycle and severely hampered EPA’s ability to assess high production volume (HPV) chemicals under its ill-fated ChAMP Initiative.

So how will the chemical industry react?  Here’s why I’ll be watching intently.  Read More »

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Exceptions swallow the rule: “Rare cases” turn into daily approvals for dispersant use

By / Published: July 7, 2010

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

What the EPA hath sought to take away from BP, the US Coast Guard hath given back.

Remember the May 26 Directive that, well, directed BP to “eliminate the surface application of dispersants” except in “rare cases when there may have to be an exemption” and where BP submits a written request and receives an exemption in writing from the Federal On-Scene Coordinator (FOSC, currently Admiral James Watson of the Coast Guard)?

Naturally, I was curious about the nature and number of such exemptions, given that, as I noted earlier, surface application of dispersants has continued since the May 26 Directive.  After I (and others, I expect) made inquiries a couple of weeks ago to get copies of the written requests from BP and written approvals from the FOSC, the Coast Guard has informed me that it has posted these documents on the Deepwater Horizon response website.

These documents reveal that, as of June 30 (the last day for which a document has been posted as of this writing), more than 40 exemption requests have been submitted – and approved.  These exemptions have allowed surface application of dispersant to occur virtually every day since the Directive was issued.

The documents also hold some other interesting details as to the rationales offered for the exemptions and the nature of the approvals.  Read More »

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EPA clarifies it wants more information on those dispersants made public

By / Published: June 9, 2010

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

EPA issued a statement today drawing attention to its posting on its website late last week of the ingredients in NALCO’s Corexit® dispersants, more than one million gallons of which have now been released into the Gulf of Mexico.  The statement appears to have been issued in response to queries from myself and others as to why the posting was not more prominently flagged by EPA.  It indicates that the most recent disclosure “was possible because NALCO waived their claim” that the ingredient identities are proprietary.  It also makes clear EPA doesn’t consider Nalco’s disclosure to be the end of the story, and that EPA will continue to seek to provide the public with more information about the dispersants than their producers have produced to date.

I’ve posted EPA’s statement just beyond this jump. Read More »

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Presto: Corexit® dispersant ingredients revealed

By / Published: June 8, 2010

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

With no fanfare whatsoever, a list of the ingredients in the Corexit® dispersants has been posted on EPA’s website.  I can’t say when the list appeared — I was pointed to it by Elana Schor, a reporter with E&E News, who discovered the list a little earlier today, buried well down on the agency’s dispersants page.

The components of COREXIT® 9500 and 9527 are:

CAS Registry Number Chemical Name
57-55-6 1,2-Propanediol
111-76-2 Ethanol, 2-butoxy-
577-11-7 Butanedioic acid, 2-sulfo-, 1,4-bis(2-ethylhexyl) ester, sodium salt (1:1)
1338-43-8 Sorbitan, mono-(9Z)-9-octadecenoate
9005-65-6 Sorbitan, mono-(9Z)-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivs.
9005-70-3 Sorbitan, tri-(9Z)-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivs
29911-28-2 2-Propanol, 1-(2-butoxy-1-methylethoxy)-
64742-47-8 Distillates (petroleum), hydrotreated light

More to come.

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