{"id":1045,"date":"2010-12-09T07:21:41","date_gmt":"2010-12-09T12:21:41","guid":{"rendered":"http:\/\/blogs.edf.org\/nanotechnology\/?p=1045"},"modified":"2025-06-18T10:29:50","modified_gmt":"2025-06-18T15:29:50","slug":"a-bright-spot-in-industry-ngo-dialogue-on-tsca","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2010\/12\/09\/a-bright-spot-in-industry-ngo-dialogue-on-tsca\/","title":{"rendered":"A bright spot in industry-NGO dialogue on TSCA"},"content":{"rendered":"

Richard Denison, Ph.D., is a Senior Scientist.<\/em><\/em><\/p>\n

A couple of weeks ago, a short letter<\/a> was sent to the Environmental Protection Agency (EPA) under this rather unusual letterhead:<\/p>\n

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\"\"<\/a><\/p>\n

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The letter noted:\u00a0 \u201cOur three organizations have been working together to discuss how best to achieve effective processor reporting of use and exposure information, which is a clear demonstration of our mutual interest in providing EPA with reliable use and exposure information on chemicals in commerce.\u201d<\/p>\n

What’s up with that?\u00a0 <\/p>\n

The decision to send such a letter was actually the culmination of two years of constructive dialogue toward finding common ground between business, health and environmental interests on the contentious issues surrounding implementation of the Toxic Substances Control Act (TSCA).<\/p>\n

I, along with my colleague Andy Igrejas, director of the Safer Chemicals, Healthy Families<\/em><\/a> coalition, just got back from the annual conference of the Consumer Specialty Products Association (CSPA), the trade association for the formulated chemical products industry.\u00a0 We both had been invited by CSPA to speak on a panel on TSCA reform, and to meet with company representatives working on proposals for various elements of such reform.<\/p>\n

Two years earlier, I attended the same conference for the first time and presented a summary of a paper I had just published, titled Ten Essential Elements of TSCA Reform<\/em><\/a>.\u00a0 A bit to my surprise, my paper was well-received, and it led to a series of meetings with CSPA companies and staff that \u201cgot into the weeds\u201d on the specifics of TSCA enhancements and implementation issues.\u00a0 While I attended the initial meetings by myself, more recently several members of our coalition have become involved.<\/p>\n

What\u2019s worked and why<\/strong><\/p>\n

There are two characteristics of what CSPA has done that, in my view, have distinguished it from other efforts at dialogue in which I have been involved during this period, and have made it more substantive and fruitful.\u00a0 First, CSPA set up a number of workgroups on specific issues that were each led by technical and policy specialists drawn from its member companies, not by CSPA staff.\u00a0 Second, those workgroups developed and shared specific, often detailed proposals, not just principles or generalities.<\/p>\n

The ability to share and compare and contrast concrete proposals from both sides of the table has fostered better understanding of our respective needs and concerns.\u00a0 And it has brought into sharper focus questions we need to address as to the scale of change needed and the practicalities of implementing those changes.<\/p>\n

Now, I don\u2019t want to be too Pollyanna-ish here:\u00a0 There are clear differences in our perspectives, we\u2019ve encountered disagreements on key details, and we still have a ways to go in these discussions. \u00a0\u00a0But that\u2019s the point:\u00a0 One can\u2019t narrow differences and resolve disagreements without first clearly elucidating them.\u00a0 And that requires both sides to come to the table with specifics and an honest aim to look for ways to resolve differences.<\/p>\n

What hasn\u2019t worked<\/strong><\/p>\n

Now, while it\u2019s certainly no secret, this dialogue has proceeded out of broad public view.\u00a0 Other forums, especially the public debate over TSCA reform, have proceeded less productively.\u00a0 That, in my opinion, is because, with few exceptions, only one side \u2013 ours \u2013 has been willing to put forth specific positions and provisions and advocate for them in the public arena.\u00a0 And while our side has consistently been represented by a range of individuals drawn from our coalition\u2019s diverse membership, all too often the industry side has operated through its trade associations and has sought to limit expressions of the diversity of perspective, opinion and creative ideas that surely exists among their members.<\/p>\n

Readers of this blog know that in recent months, I have been quite critical of a number of the chemical industry\u2019s tactics and positions<\/a>.\u00a0 EDF has a long history of watch-dogging both EPA\u2019s and the chemical industry\u2019s activities associated with TSCA implementation.\u00a0 We\u2019ve consistently called things like we see them, so it should come as no surprise that we continue to do so.<\/p>\n

As EPA has re-energized its chemicals management programs<\/a>, something I believe was long overdue, we have closely monitored the chemical industry\u2019s reactions to what, in the larger scheme of things, has to be regarded as a rather modest set of steps EPA is taking under its limited current TSCA authority.<\/p>\n

The American Chemistry Council\u2019s (ACC\u2019s) statements and principles relating to TSCA reform have provided a new lens through which to view the positions the chemical industry has taken in response to EPA\u2019s regulatory proposals.\u00a0 Early on, I made clear that how ACC responded would be a good test of how serious it is about real TSCA reform.\u00a0 See here<\/a> and here<\/a>.<\/p>\n

Many of my posts have contrasted ACC\u2019s statements and principles for TSCA reform with its actual actions and positions \u2013 finding numerous cases where the two simply don\u2019t line up.\u00a0 That finding extends to ACC\u2019s responses both to others\u2019 TSCA reform proposals<\/a> and to EPA\u2019s new regulatory efforts.<\/p>\n

Looking forward<\/strong><\/p>\n

EDF will continue to scrutinize the chemical industry\u2019s actions and positions, and to criticize them whenever warranted.\u00a0 That\u2019s part of who we are and what we do.<\/p>\n

But we can walk and chew gum at the same time:\u00a0 None of our criticism should call into question our willingness to seriously engage in substantive dialogue with anyone in the chemical industry toward finding a path forward on TSCA reform.<\/p>\n

I set only two requirements:\u00a0 That the parties come forward prepared to get into the weeds, willing to offer specific proposals and work toward narrowing and resolving differences in good faith.\u00a0 And that the companies who will be the ones to implement changes take the lead in this effort.<\/p>\n

Those two elements have served well to date in our constructive dialogue with CSPA\u2019s member companies.\u00a0 And you have to admit that letterhead looks pretty nice.<\/p>\n","protected":false},"excerpt":{"rendered":"

Richard Denison, Ph.D., is a Senior Scientist. A couple of weeks ago, a short letter was sent to the Environmental Protection Agency (EPA) under this rather unusual letterhead:           The letter noted:\u00a0 \u201cOur three organizations have been working together to discuss how best to achieve effective processor reporting of use and …<\/p>\n","protected":false},"author":100,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[44,114108],"tags":[39150,39200,5021,5020],"coauthors":[],"class_list":["post-1045","post","type-post","status-publish","format-standard","hentry","category-policy","category-tsca","tag-american-chemistry-council","tag-consumer-specialty-products-association-cspa","tag-chemical-industry-tactics","tag-safer-chemicals-healthy-families"],"acf":[],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/1045","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/users\/100"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/comments?post=1045"}],"version-history":[{"count":2,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/1045\/revisions"}],"predecessor-version":[{"id":13231,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/1045\/revisions\/13231"}],"wp:attachment":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media?parent=1045"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/categories?post=1045"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/tags?post=1045"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/coauthors?post=1045"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}