EDF Health

Selected tag(s): Exposure and hazard

A sea of red herrings is behind opposition to EPA’s proposal to enhance chemical reporting

By Richard Denison / Published: April 7, 2011

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

With the chemical industry and now Congressional Republicans mounting a last-minute effort to derail the EPA’s long-time-in-coming enhancements to its Inventory Update Reporting (IUR) rule (see our last post), it’s worth examining their main objections.  That examination reveals a sea of red herrings.  Here are a few of the smelliest ones, discussed in detail in this post:

Red herring #1:  EPA has failed to indicate how it will use the information it collects.

Red herring #2:  Small businesses would be excessively burdened.

Red herring #3:  More frequent reporting is a “needless” burden on the industry.

Red herring #4:  EPA is expanding the IUR from data reporting to data-gathering.

Red herring #5:  EPA’s requirement for retroactive reporting is unfair.

Red herring #6:  Requiring electronic reporting is too inflexible.

Read More »

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A near-sisyphusian task: EPA soldiers on to require more testing under TSCA

By Richard Denison / Published: January 5, 2011

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

The Environmental Protection Agency (EPA) announced yesterday that it has finalized a rule requiring testing [UPDATE 1/7/11:  The published rule is available here] to determine basic health and environmental effects for 19 high production volume (HPV) chemicals.  While I welcome this as well as any other effort to close the huge safety data gaps that exist even for the most widely used chemicals, the back story behind this rule reveals why it is actually a perfect poster child for what’s wrong with the Toxic Substances Control Act (TSCA).

For starters, consider that it took EPA two and a half years to move the rule from the proposed stage to finalization.  And that doesn’t count the several preceding years EPA had to spend developing information sufficient to make the findings it has to make to justify proposing a test rule.

Then consider that the rule addresses only 19 of the many hundreds of HPV chemicals on the market today for which even the most basic, “screening level” hazard data are not publicly available.

And it gets worse.  Read More »

Posted in Health policy, Regulation / Also tagged , , , , | Read 1 Response

Public health advocates to the chemical industry: Stop hobbling EPA

By Richard Denison / Published: October 12, 2010

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

Today, EDF joined with 32 other environmental justice, health and environmental organizations to file comments [PDF] with EPA that strongly support its effort to improve its ability to obtain – and share with the public – robust information about the production, processing and use of chemicals in the U.S.

While the details of EPA’s proposed rule and many of our comments are heavily wonky, the motivation and goals are far from it:  To make sure that EPA, the marketplace and the public have the information they need to guard against harm from dangerous chemicals.  That requires knowing a whole lot more than we do today about what chemicals are in commerce, in what quantities, how they’re used – essential to understanding how we may be exposed.

Robust information is the lifeblood of a sound chemicals management system.  Government needs access to comprehensive, reliable information to inform policy, programmatic and regulatory decisions it must make to carry out its mission.  The market needs access to such information to inform the myriad decisions made every day by producers, sellers and users of chemicals and products and materials made using chemicals.  And researchers, the public and groups that work in the public interest need access if they are to have confidence in, and be able meaningfully to contribute to, decisions and actions taken by government and the private sector.

In an earlier post, we made the point that the chemical industry’s reactions to these modest proposals will be a litmus test for how serious it is in acting on its rhetoric about the need for EPA and the public to have more and better information on chemicals.  With the comment period closing today for EPA’s proposed rule, look here in the coming weeks for our assessment on industry’s comments.

What follows is a summary of our comments, indicating both what we support and what more is needed.  Read More »

Posted in Health policy, Industry influence, Regulation / Also tagged , , | Comments are closed

Sludging through the nano lifecycle: Caution ahead

By Richard Denison / Published: September 23, 2010

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

Researchers at Virginia Tech have identified and characterized silver nanoparticles (AgNPs) in the sewage sludge produced by an operating municipal wastewater treatment plant.  The study is notable in several respects:  It is the first time AgNPs have been detected in a field-scale study, one of a real-world operation representative of a real-world exposure scenario to boot.  It shows that silver can exist in wastewater treatment products as nanoparticles.  It indicates such particles may be most likely to partition to sludge under common treatment technologies.  And it suggests that silver may be chemically transformed in the course of wastewater treatment.

The study did not demonstrate that the AgNPs detected in the sludge originated from products containing such nanoparticles, as some news stories have suggested, although the authors indicate such a source “is likely.”  But the findings have important implications for nano safety nonetheless.  Read More »

Posted in Nanotechnology / Also tagged , | Read 2 Responses

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

By Richard Denison / 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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Not playing nice: The American Chemistry Council solidifies its claim to being the “industry of no”

By Richard Denison / Published: July 30, 2010

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

If you had any doubt when reading my post earlier this week that the chemical industry isn’t serious about real TSCA reform, watch American Chemistry Council (ACC) President and CEO Cal Dooley’s hard-line performance at yesterday’s hearing before a subcommittee of the House Energy and Commerce Committee (video link at the bottom of this page).  The legislative hearing focused on H.R. 5820, the Rush-Waxman Toxic Chemicals Safety Act of 2010 that was introduced last week.

All the themes I struck in my earlier blog post Mr. Dooley played out in spades:  more loud and long complaints aimed at every aspect of the bill; placing the worst possible interpretation on any provision subject to interpretation; playing the China and job-loss cards over and over; and last but not least, offering not a single constructive proposal of his own for reform.

A very different industry voice was also at the witness table, however – Howard Williams, V.P. & General Manager of the Pennsylvania division of Construction Specialties.  Mr. Williams deftly countered all of ACC’s theatrics, embracing all of the bill’s key provisions and making a strong business case for them.  Read More »

Posted in Health policy, TSCA reform / Also tagged , , , , , , | Read 1 Response