{"id":1214,"date":"2011-03-14T12:05:46","date_gmt":"2011-03-14T17:05:46","guid":{"rendered":"http:\/\/blogs.edf.org\/nanotechnology\/?p=1214"},"modified":"2024-02-12T11:01:11","modified_gmt":"2024-02-12T16:01:11","slug":"acc-endorses-cumulative-impact-assessment-for-all-tsca-regulations","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2011\/03\/14\/acc-endorses-cumulative-impact-assessment-for-all-tsca-regulations\/","title":{"rendered":"ACC endorses cumulative impact assessment for all TSCA regulations!"},"content":{"rendered":"

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

In what seemed a startling move, the American Chemistry Council (ACC) last week gave testimony at a Congressional hearing<\/a> that included a full-throated endorsement of mandating that EPA be required to assess cumulative impacts<\/a> when developing regulations addressing chemicals under the Toxic Substances Control Act (TSCA).<\/p>\n

The call for cumulative impact assessment was a contentious element in last year\u2019s debate over the safety standard that would apply to chemicals under a reformed TSCA.\u00a0 Reform advocates supported assessing such impacts where the science allows<\/a>, while ACC had staunchly opposed the concept<\/a>.\u00a0 The need to account for cumulative impacts is also a key recommendation of the National Academy of Sciences, in its recent reports Science and Decisions:\u00a0 Advancing Risk Assessment<\/em><\/a> (2009) and Phthalates and Cumulative Risk Assessment:\u00a0 The Tasks Ahead<\/a><\/em>\u00a0(2008).<\/p>\n

Ah, but the devil is indeed in the details:\u00a0 ACC\u2019s apparent change of heart is no such thing.\u00a0 Rather, ACC is endorsing a step that would make it even harder for EPA to act to control dangerous chemicals under TSCA, namely that the agency would have to consider the cumulative impact of all prior regulations affecting a given industry before it could propose a\u00a0 new one.\u00a0As reasonable as that sounds, when added to an already dizzying array of hoops EPA must jump through to get any regulation through the rulemaking process, its practical effect will be to further stymie EPA\u2019s efforts to protect people and the environment from toxic chemical exposures.<\/p>\n

And whatever its merits, ACC\u2019s endorsement of the concept of cumulative impact assessment in one context even as it rails against it in another begs the question:\u00a0 Why isn\u2019t what\u2019s good for the goose also good for the gander?<\/p>\n

To see what I mean, let\u2019s try out a little rewrite of some of ACC\u2019s statements<\/a>.<\/p>\n

ACC said:\u00a0 \u201cIt is imperative that we have an accurate understanding of the impact of proposed regulations on industry. \u00a0The full regulatory burden for a particular sector can only be known if the cumulative impact of overlapping regulations is identified.\u201d<\/p>\n

We say:\u00a0 \u201cIt is imperative that we have an accurate understanding of the impact of chemical exposures on people<\/span>. \u00a0The full health<\/span> burden for a particular population<\/span> can only be known if the cumulative impact of overlapping exposures<\/span> is identified.\u201d<\/p>\n

ACC said:\u00a0 \u201cThe lack of cumulative impact assessments is a fundamental shortcoming in the way government agencies develop and evaluate proposed rules.\u201d<\/p>\n

We say:\u00a0 \u201cThe lack of cumulative impact assessments is a fundamental shortcoming in the way government agencies develop and evaluate chemical risk assessments<\/span>.\u201d<\/p>\n

ACC recommended:\u00a0 \u201cTrack the sectors affected by new regulations so the most heavily regulated sectors can be easily identified and regulations can be streamlined appropriately.\u201d<\/p>\n

We recommend:\u00a0 \u201cTrack the populations<\/span> affected by chemical exposures<\/span> so the most heavily exposed populations<\/span> can be easily identified and regulations can be targeted<\/span> appropriately.\u201d<\/p>\n

Gosh, that only makes sense.<\/p>\n

Seems like ACC likes cumulative impact assessment when it thinks it can protect the health of the chemical industry, but fights it tooth-and-nail when it comes to protecting the health of the rest of us.<\/p>\n","protected":false},"excerpt":{"rendered":"

Richard Denison, Ph.D., is a Senior Scientist. In what seemed a startling move, the American Chemistry Council (ACC) last week gave testimony at a Congressional hearing that included a full-throated endorsement of mandating that EPA be required to assess cumulative impacts when developing regulations addressing chemicals under the Toxic Substances Control Act (TSCA). The call …<\/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":[44,56096],"tags":[39150,39162,5021,39160,5017],"coauthors":[],"class_list":["post-1214","post","type-post","status-publish","format-standard","hentry","category-policy","category-omboira","tag-american-chemistry-council","tag-cumulative-exposure","tag-chemical-industry-tactics","tag-national-academy-of-sciences-nas","tag-risk-assessment"],"acf":[],"aioseo_notices":[],"aioseo_head":"\n\t\t\n\t\n\t\n\t\n\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t