EDF Health

No orphan left behind: Health and environmental NGOs support EPA’s proposed paired rules to address high production volume “orphan” chemicals

By / Published: January 18, 2012

Richard Denison, Ph.D., is a Senior Scientist.  Allison Tracy is a Chemicals Policy Fellow.

Environmental Defense Fund today submitted comments along with 15 other health, environmental justice and state and national environmental organizations, in support of EPA’s proposed rule to address the final batch of 45 “orphan” chemicals that were never sponsored under the agency’s earlier High Production Volume (HPV) Challenge Program.

An earlier post to this blog highlighted and applauded the novel, innovative and efficient approach EPA has proposed, which actually entails the coupling of two rules:

(1) a test rule for 23 of these HPV chemicals for which EPA can make the requisite exposure findings to require testing, combined with:

(2) a Significant New Use Rule (SNUR) for the other 22 HPV chemicals for which EPA cannot presently make such findings, which requires companies to notify EPA if their production or use of those chemicals changes so as to increase the potential for exposure and then warrant testing.

The comments we filed today reiterate our strong support for this approach – and propose that the same approach be extended to several additional batches of HPV chemicals that still lack a basic set of hazard data.

Read More »

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REACH starts to earn its “A”: 20 chemicals headed to the Candidate List and 13 to Authorization

By Allison Tracy / Published: December 21, 2011

Allison Tracy is a Chemicals Policy Fellow. Richard Denison, Ph.D., is a Senior Scientist.

The European Chemicals Agency (ECHA) has been busy this week implementing the EU’s chemical regulation, REACH (short for Registration, Evaluation, Authorization and Restriction of Chemicals).

On Monday, ECHA announced it has added 20 more Substances of Very High Concern (SVHCs) to REACH’s Candidate List.  These SVHCs are now eligible for later addition to Annex XIV, the list of SVHCs subject to Authorization.

Separately, the agency today forwarded its final recommendation that 13 chemicals already on the Candidate List be formally added to Annex XIV.  (We had blogged earlier about ECHA’s initial recommendation proposing these 13 SVHCs for Authorization.)  If the European Commission confirms this addition, after a specified sunset date, the use of these will be allowed only if specifically authorized by EU authorities.  Read More »

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Making do under TSCA: EPA to require reporting of health data by makers of chemicals used in hydraulic fracturing

By / Published: December 9, 2011

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

Last August, Earthjustice, Environmental Defense Fund (EDF) and over one hundred other groups recently filed a petition under the Toxic Substances Control Act (TSCA) calling on the Environmental Protection Agency (EPA) to require manufacturers and processors of chemicals used in oil and gas exploration and production (E&P chemicals) – including those used in hydraulic fracturing fluids – both to conduct testing and submit to EPA health and environmental data they already have on hand..  The aim of the petition was to ensure EPA obtains better information on the identity, production, use and health/environmental effects of these chemicals in order to evaluate their health and environmental risks.  Late last month, EPA announced its decision.  Read More »

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Twin dangers from TCE: Widespread exposure, and now a strong link to Parkinson disease

By Jennifer McPartland / Published: November 22, 2011

Jennifer McPartland, Ph.D., is a Health Scientist.

A study published online in the Annals of Neurology last week, “Solvent Exposures and Parkinson Disease Risk in Twins,” adds to scientific evidence linking exposure to the solvent trichloroethylene, or TCE, and other common solvents with onset of Parkinson disease.  Parkinson disease is a debilitating condition well known for symptoms of trembling but can also include slowed motion, impaired posture and balance, and loss of automatic movements (e.g. blinking, arm swaying when walking).  Most unfortunately, it has no cure. 

According to the authors, this new twin study is the first confirmation in a population-based study of a significant association between exposure to TCE and incidence of Parkinson disease.    Read More »

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EPA proposes yet another TSCA workaround: Creative, yes, but why not just give it the authority it needs?

By / Published: November 2, 2011

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

One thing I’ve learned in observing EPA try to operate under the Toxic Substances Control Act (TSCA) over the years is that – faced with limited authority and significant evidentiary and resource burdens – the Agency often has to resort to a workaround to get something it needs to do done.

Can’t ban a nasty chemical?  Wait until it’s voluntarily withdrawn and then pounce on it with a Significant New Use Rule (SNUR) to try to wedge the door closed.  Witness PFOS and penta and octaBDE.  (Under TSCA, without a SNUR in place on a chemical, a new producer or importer could start up without even letting EPA know; where EPA has issued a SNUR for a chemical, advance notification is required and EPA least has a chance to weigh in before production or import proceeds.)

Can’t require an up-front minimum data set for new chemicals?  Recommend to companies that for certain chemicals they submit such a data set along with the pre-manufacturing notice (PMN) they’re required to file, or risk having EPA extend the review of their new chemical or negotiate with them to do the testing.  EPA has made such “recommendations” for those relatively few new chemicals where the company “anticipates” at the outset producing it in large amounts in the first three years or where significant release or exposure is projected. 

The latest such workaround?  EPA’s simultaneous issuance of a proposed test rule and a proposed SNUR for a batch of high production volume (HPV) “orphan” chemicals that no company agreed to sponsor under the Agency’s voluntary HPV Challenge Program.

Necessity is the mother of invention, they say, and these creative new proposals are a case in point.  But, my oh my, there’s gotta be a better way…. Read More »

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Expansion of my critique of the ACC tool’s persistence and bioaccumulation criteria

By / Published: September 29, 2011

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 »

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