EDF Health

Selected tag(s): Significant New Use Rule (SNUR)

EPA’s New Chemicals Program: TSCA dealt EPA a very poor hand

By / Published: April 16, 2009

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

[The first post in this series can be found here.]

Some in the chemical industry point to EPA’s New Chemicals Program as a robust program, one that could serve as a model for reform of the Toxic Substances Control Act (TSCA).  Most recently, the National Petrochemical & Refiners Association (NPRA) did so in its testimony at a recent House of Representatives subcommittee’s TSCA oversight hearing.  So just how robust is EPA’s program on new chemicals?  Read More »

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EPA’s Nano Consent Order, Part II: What About the Lifecycle?

By / Published: October 13, 2008

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

Since my first post concerning EPA’s Consent Order, I’ve been reflecting further on the management conditions it imposes – or, more accurately, on what conditions it doesn’t impose.  The Order’s only such conditions address potential worker exposure.  What about the rest of the nanomaterial’s lifecycle? Read More »

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

Fixing TSCA for Nano: Don’t Forget All the Other Chemicals!

By / Published: July 28, 2008

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

A growing number of observers of nanotechnology policy in the U.S. – at least those outside the U.S. government! – recognize that the Toxic Substances Control Act (TSCA) is poorly suited both to spur the generation of sufficient information about nanomaterials, and to ensure that information indicating potential risks will trigger meaningful action.  So why not just tweak TSCA to make it work better for nano? Read More »

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EPA Nano Authority under TSCA, Part 2: “New” Isn’t Necessarily All That Better

By / Published: May 27, 2008

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

[Links to posts in this series: Part 1, Part 2, Part 3, Part 4, Part 5]

In my last post, I decried EPA’s shortsighted decision to declare nano forms of chemicals listed on the Toxic Substances Control Act (TSCA) Inventory to be “existing” rather than “new” chemicals.  But I noted that EPA did not rule that all nanomaterials are existing chemicals.  EPA says it will consider buckyballs, carbon nanotubes, or anything else that has no counterpart – a substance with the same chemical structure – already on the TSCA Inventory to be “new.”  So can we rest assured that, at least for these nanomaterials, EPA has sufficient authority under TSCA to effectively identify and address their potential risks?  Would it were so.  Read More »

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