EDF Health

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

Part 4 of a 4-part series – see Part 1, Part 2, and Part 3 here

This series of blog posts is looking ahead toward opportunities to advance a more robust and holistic vision for implementing the Toxic Substances Control Act (TSCA) as reformed in 2016.

We discussed in the preceding installments of this series the importance of ensuring that combined exposures to a chemical from multiple sources and the greater exposures and susceptibilities of certain groups are accounted for.  But it is critical to also recognize that many other factors influence the impacts chemical exposures have on our health.  This final installment in our series will discuss how TSCA can and should take into account all of these factors – that is, account for cumulative impacts.

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

Part 3 of a 4-part series – see Part 1, Part 2, and Part 4 here

This series of blog posts is looking ahead toward opportunities to advance a more robust and holistic vision for implementing the Toxic Substances Control Act (TSCA) as reformed in 2016.

In the preceding installment in this series, we discussed TSCA’s mandate for EPA to conduct comprehensive chemical evaluations.  The Trump EPA’s failure to do so especially detrimental to those groups at greater risk because they are more likely to face the precise exposures and susceptibilities that the Trump EPA excluded.  In this installment of our series, we will address how TSCA can and must be used to better protect those at greater risk from chemical exposures.

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

Part 2 of a 4-part series – see Part 1, Part 3, and Part 4 here

After our look back in Part 1 of this series at the damage done over the past four years, the remainder of the series will look ahead and explore opportunities to advance a more robust and holistic vision for implementing the Toxic Substances Control Act (TSCA) as reformed in 2016.

In this installment, we will discuss why legal and effective TSCA implementation demands that EPA undertake comprehensive assessments of chemical risks that supersede the media-specific limitations of other environmental laws. Read More »

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

Part 1 of a 4-part series – see Part 2, Part 3, and Part 4 here

It wasn’t that long ago, June 2016, when there was hope that our nation was at last embarking on the enormous task of reinvigorating and greatly strengthening our chemical safety system, 40 years after original passage of the moribund Toxic Substances Control Act (TSCA).

Passage of the Frank R. Lautenberg Chemical Safety for the 21^st Century Act by huge bipartisan majorities in both houses of Congress seemed to bode well for robust implementation of the law by the Environmental Protection Agency (EPA).  Even the affected industry had accepted the reforms as essential to restoring public confidence in our federal system (hoping thereby also to stem the rising tide of actions by state governments, retailers, and others to fill the void left by EPA’s inability to ensure the safety of chemicals and products).

We have an opportunity to rethink how the law could and should be used to advance a broader vision of greater health and environmental protection for all people.

Labor and health and environmental public interest communities saw an opportunity to use the new TSCA to drive more thorough assessments of chemicals’ risks.  The failure of our risk assessment-based regulatory system to address the multiple sources of exposure to a chemical affecting many different groups of people had long been viewed as a fundamental flaw of the old law.  Fixing that flaw isn’t, unfortunately, how the last four years have gone.

As we look to the future, there is a pressing need to course-correct on TSCA implementation.  But there is also an opportunity to rethink how the law could and should be used to advance a broader vision of greater health and environmental protection for all people.  This series of blog posts will explore that potential.

But we must start with a brief look back at the damage done.  Read More »