Richard Denison, Ph.D., is a Senior Scientist. Allison Tracy is a Chemicals Policy Fellow.
Well, in its comments on EPA’s proposed rule to enhance chemical information reporting under the TSCA Inventory Update Rule (IUR), it took the American Chemistry Council (ACC) all of 5 paragraphs to get through the lip service it no doubt felt it had to pay to supporting EPA’s proposals “in principle,” and then proceed to devote 31 pages to arguments opposing virtually every element of EPA’s proposals.
Cunningly on its part, ACC’s arguments often do not oppose outright the EPA proposals. Rather, it seeks to put off their implementation for as long as possible. EPA’s proposed rule calls for reporting in 2011 that would provide information for years 2006 and forward. In contrast, ACC would have EPA put off implementation of all of its proposed IUR enhancements, with the result that both EPA and the public would not get any of the additional information until at least 2015.
Like we said in the title of this post: Reporting deferred is right-to-know denied.
We’ll be posting more about ACC’s comments in the coming weeks, but in this post, we’ll consider the core argument ACC makes for deferral: that “the business of chemistry is product-focused, not substance focused.” ACC would have us believe their member companies don’t know what chemicals are in any of the products (i.e., mixtures of chemicals) they make and sell.
This argument warrants – ahem – additional scrutiny. Read More