EDF Health

Selected tag(s): Data requirements

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

By Richard Denison / 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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New Ways in the Ancient World: Japan and China advance their chemicals policies

By Allison Tracy / Published: October 5, 2011

Allison Tracy is a Chemicals Policy Fellow.

This isn’t the first time on this blog that we’ve observed that chemicals reform is popping up all over the world.  Whatever their strengths and shortcomings, the 1999 amendments to the Canadian Environmental Protection Act and the European Union’s REACH Regulation got the ball rolling.  The momentum of chemicals reform is reaching around the globe as governments pay more attention to the risks posed by chemicals.  In this post, we will focus on recent developments in Japan and China.

Japan and China are two of the U.S.’s top competitors, so it’s noteworthy that they have not allowed themselves to fall behind in chemicals management.  Why are they expanding their chemicals regulations?  Do they know something we don’t?  Read More »

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ACC’s chemical prioritization tool: Helpful, but flawed and off the mark for EPA to use without TSCA reform

By Richard Denison / Published: September 20, 2011

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 »

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A most-pressing Health Affair: Acting as if our children’s health matters

By Richard Denison / Published: May 5, 2011

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

Health policy history of sorts was made this week:  The prestigious journal Health Affairs, the nation’s leading journal of health policy, unveiled its first-ever issue devoted entirely to environmental health.  It did so via a briefing held in Washington, DC on Wednesday that featured several pre-eminent environmental health experts, including David Fukuzawa, Program Director for Health at The Kresge Foundation; Linda Birnbaum, Director of the National Institute of Environmental Health Sciences (NIEHS); and Kenneth Olden, Professor and Founding Dean at the new City University of New York’s School of Public Health and former long-time NIEHS Director.

A sneak peak has been provided via advanced publication of some of the journal issue’s articles.  Prominent among the themes of these articles:  The high and increasing health and economic costs of unregulated exposures to unsafe and inadequately tested chemicals.

I’ll call attention here to two papers in particular:

Read More »

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Pediatricians: Reform TSCA to protect kids. ACC responds (a la W.C. Fields): We love kids, too

By Richard Denison / Published: April 26, 2011

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

A long-awaited and full-throated endorsement of comprehensive reform of the Toxic Substances Control Act (TSCA) from the venerable American Academy of Pediatricians (AAP) was published online yesterday in the journal Pediatrics.

Right down the line, the AAP’s 8-page policy statement calling for a wholesale overhaul of TSCA mirrors the recommendations of health and environmental advocates, academic researchers and just about anyone else who has paid attention to the mounting body of evidence documenting the linkages between rising chemical exposures and adverse effects on the health of our population, especially the most vulnerable among us:  the developing fetus, infants and young children.

The AAP’s recommendations also closely track key provisions in TSCA reform bills introduced last year in both Houses of Congress as well as the Safe Chemicals Act of 2011 just re-introduced in the U.S. Senate this month.

This latest statement from the Academy adds it to the list of other major medical and health associations that have previously called on Congress to  revamp TSCA, including the American Medical Association, the American Public Health Association and the American Nurses Association.

Given this growing chorus, it is perhaps not surprising that the American Chemistry Council (ACC) would seek to worm its way in to claim that it, too, loves kids and supports TSCA reform.

But dig a bit deeper, and what is most striking is that ACC stridently opposes essentially every element of TSCA reform called for by the American Academy of Pediatrics.  Read More »

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TSCA reform 2.0, aka, Safe Chemicals Act of 2011: Tastes great, less filling

By Richard Denison / Published: April 14, 2011

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

The Safe Chemicals Act of 2011 was introduced in the U.S. Senate today by Senator Frank Lautenberg and is co-sponsored by Senators Amy Klobuchar, Charles Schumer, and Barbara Boxer.

In the TSCA reform debate, some things haven’t changed from last year:  TSCA is just as badly in need of an overhaul, and consumers and the chemical industry’s customers have no more confidence in the safety of chemicals in use today than they did a year ago.  States, other countries and the marketplace all continue to act to advance modern chemical safety policies and practices.  We in the advocacy community are still waiting for the chemical industry to offer some of its own proposals for reform – though some individual companies and product associations have been more forthcoming.

In contrast, the 2011 version of the Safe Chemicals Act has changed in some important ways – and for the better.  It includes a number of improvements over last year’s version that would both boost health protections and ease implementation and workability.

[Updated 5-9-11:  Here’s a side-by-side comparing the 2011 version to the 2010 version of the Act.]  Read More »

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