EDF Health

Selected tag(s): High Production Volume (HPV)

EPA identifies another risky chemical: Can it succeed in using TSCA to restrict it?

By Lindsay McCormick / Published: March 31, 2015

Lindsay McCormick is a Research Analyst.

Last week, EPA released a risk assessment on the chemical N-Methylpyrrolidone (NMP).  NMP is produced and imported into the U.S. in huge quantities (184 million pounds reported in 2012), and has a variety of uses including petrochemical processing, making plastics, and paint stripping.

Experiments in laboratory animals demonstrate that exposure to NMP during pregnancy leads to adverse developmental outcomes in the offspring, such as low birth weight, skeletal malformations, and mortality (see here and here).

EPA’s assessment focused exclusively on NMP exposure from its presence in products used to remove paint and other coatings.  Because of NMP’s potential to disrupt fetal development, EPA assessed exposures in women of childbearing age.

EPA found that exposure to NMP-based paint strippers in women of childbearing age beyond four hours per day presents risks that cannot be mitigated from use of protective gear such as gloves and respirators.  Risks obviously could be greater, even for shorter exposure times, if protective equipment is not consistently used.   Read More »

Posted in Health policy, Regulation, TSCA reform / Also tagged | Comments are closed

No shame: ACC plunges to new low in fighting your right to know

By / Published: May 21, 2012

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

This post is longer than usual and starts with a rather esoteric topic, but I urge you to read it through, as it vividly shows there is no limit to the lengths to which the American Chemistry Council (ACC) will go to squirm out of a regulatory requirement, even if it means violating rules by which ACC had agreed to abide.

But that’s far from the worst of it.  Going farther than even I could imagine when I blogged earlier about its tactics, ACC is sparing no effort to deny your right to know about the health impacts of chemicals, by mustering every argument it can invent – however far-fetched – to  keep health and safety studies from being shared with the public.

ACC insists that the U.S. Environmental Protection Agency (EPA) should hassle the European Union (EU) instead of its members for the health and safety data ACC promised to provide – despite the fact that the chemical industry itself has thrown up major roadblocks to such sharing.  And reaching a new low in tortured logic, ACC argues that, should EPA succeed in getting its hands on the health and safety data submitted to the EU, EPA can and should deny the public access to those data – despite the fact that the Toxic Substances Control Act (TSCA) clearly prohibits EPA from withholding such information.  Read More »

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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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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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Funny name, serious concern: EPA proposes Significant New Use Rule for 14 glymes

By / Published: July 11, 2011

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

EPA today proposed a Significant New Use Rule (SNUR) that, once finalized, would mandate that companies notify EPA prior to engaging in any “significant new use” of any of the 14 chemicals EPA has identified collectively as glymes.  Among other concerns, EPA has identified their use in various consumer products and their potential to cause reproductive and developmental toxicity.  For most of the glymes, the significant new use would be any use in a consumer product beyond those that are already ongoing.  For two of these chemicals, the significant new use would be any use.

This proposed SNUR, which was mired at the Office of Management and Budget (OMB) for more than six months, is now out for a 60-day public comment period.  A SNUR is essentially the only means available to EPA under the Toxic Substances Control Act (TSCA) by which it can try to limit the use of an existing chemical of concern.  It is far from a perfect means of doing so.

Nonetheless, within its limited authority under TSCA, today’s step by EPA brings at least some degree of scrutiny over a quite nasty group of chemicals.  Read More »

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More progress under REACH: 13 more chemicals en route to the Authorization list

By Allison Tracy / Published: June 20, 2011

Allison Tracy is a Chemicals Policy Fellow.

The European Chemicals Agency (ECHA), the agency responsible for implementation of the EU’s REACH Regulation, posted a press release last week listing 13 chemicals it proposes to advance from its list of “Substances of Very High Concern” (SVHCs), also known as the Candidate List for Authorization, to its list of chemicals subject to Authorization, also known as Annex XIV.

Authorization is one of the main pillars of REACH, via which use of designated SVHCs is limited to those uses specifically authorized by EU authorities. Following the public consultation period that is now underway, some or all of the 13 chemicals will move to the Authorization list.   Read More »

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