Richard Denison, Ph.D., is a Senior Scientist.
When the chemical industry talks about prioritization – a central question in the debate over TSCA reform – more often than not it quickly reduces the question down to the argument that we should focus only on those chemicals, however hazardous or untested they may be, to which we know people are exposed. In a perfect world, that might suffice. But, as this post will explore, the world of exposure assessment is anything but perfect. Read More
Richard Denison, Ph.D., is a Senior Scientist.
Today, the American Chemistry Council (ACC) unveiled its “10 Principles for Modernizing TSCA.” Also today, the Safer Chemicals, Healthy Families coalition – of which EDF is a member – issued a news release and unveiled its 9-point “Platform for Reform of TSCA.” How do they line up? Read More
Richard Denison, Ph.D., is a Senior Scientist.
Some time back, I promised a look at whether Canada’s Chemical Management Plan provides a model for TSCA reform. This post will provide that look. Bottom line: While our neighbor to the north has undertaken and accomplished a great deal over the past decade, it has done so with one hand tied behind its back. Read More
Richard Denison, Ph.D., is a Senior Scientist.
It probably goes without saying that EDF welcomes EPA’s decision to suspend the development and posting of risk-based prioritizations under its Chemical Assessment and Mangement Program (ChAMP). EDF has been arguing (see our earlier posts) that ChAMP’s “rush to risk” has taken EPA badly off-track. But we have also identified many useful things that EPA’s existing chemicals program can and should be doing with the data it obtained through the HPV Challenge (whether called ChAMP or not) .
We look forward to working with EPA to craft a new approach, grounded in a return to developing scientifically defensible hazard, not risk, characterizations and transparently identifying and addressing data gaps and data quality problems.
Cal Baier-Anderson, PhD, is a Health Scientist.
In our critique of EPA’s Chemical Assessment and Management Program (ChAMP), we have pointed out that, despite its limitations, there is value in the hazard data that EPA is collecting and analyzing. How so? Read More
Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.
This example raises some new issues as well as some we discussed in the earlier examples: EPA relies on a highly flawed “category approach” that ignores major differences in the properties and structures of the 13 members of this category. It compounds this problem by unquestioningly accepting data from inadequate studies to assert low toxicity, rather than demanding that sufficient studies be provided. As a result, it fails to identify, let alone require to be filled, the enormous gaps in the data available for many of the category members. EPA ignores or dismisses without explanation its own earlier comments raising serious concerns about the quality and completeness of data provided by the sponsor of these chemicals under the HPV Challenge. Finally, this example once again shows how EPA’s heavy reliance on self-reported use information from manufacturers paints an incomplete and potentially very misleading picture of the actual uses of industrial chemicals. Read More