{"id":4472,"date":"2015-07-13T08:21:22","date_gmt":"2015-07-13T13:21:22","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=4472"},"modified":"2024-02-12T11:01:45","modified_gmt":"2024-02-12T16:01:45","slug":"we-dont-know-how-many-chemicals-are-in-use-today-we-should-know","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2015\/07\/13\/we-dont-know-how-many-chemicals-are-in-use-today-we-should-know\/","title":{"rendered":"We don\u2019t know how many chemicals are in use today.  We should know."},"content":{"rendered":"<p><em>Richard Denison, Ph.D.,\u00a0<\/em>is a Lead Senior Scientist.<\/p>\n<p>No one knows how many chemicals are in use today.\u00a0 It\u2019s a problem that we don\u2019t.<\/p>\n<p>The TSCA Inventory lists about 85,000 chemicals, but because it is a cumulative list that started in 1979, it lists all chemicals that have been in commerce at some point since then.\u00a0 It is not a list of chemicals currently on the market.<\/p>\n<p>EPA periodically collects information on chemicals produced or imported above a certain volume threshold (currently set at 25,000 pounds per reporting site in the reporting year).\u00a0 In <a href=\"http:\/\/www.epa.gov\/cdr\/pubs\/guidance\/cdr_factsheets.html\">the most recent data collected in 2012<\/a>, companies reported producing or importing 7,700 chemicals.\u00a0 However, given the volume threshold and the several exemptions from reporting requirements, we know this number is a significant underestimate of the number of chemicals in active commerce.<\/p>\n<p>This means that all we know is that somewhere between 7,700 and 85,000 chemicals under TSCA\u2019s jurisdiction are presently in commerce.\u00a0 I\u2019ve repeatedly heard industry and environmentalists cite each of these numbers in claims they make about how many chemicals are in use today.\u00a0 The truth, however, clearly lies somewhere within this huge range. \u00a0<!--more--><\/p>\n<p>There have been attempts before to close this data gap.\u00a0 Using its current TSCA authority, <a href=\"https:\/\/www.federalregister.gov\/articles\/2008\/11\/21\/E8-27765\/tsca-inventory-reset-and-inorganic-high-production-volume-challenge-programs-notice-of-public\">EPA proposed \u201cresetting\u201d the TSCA Inventory seven years ago<\/a>.\u00a0 The idea died, however, after industry interests opposed it as too burdensome.\u00a0 And the various iterations of the late Senator Lautenberg\u2019s earlier TSCA reform bill, the Safe Chemicals Act, <a href=\"http:\/\/thomas.loc.gov\/cgi-bin\/query\/z?c111:S.3209:\">going all the way back to 2010<\/a> featured an inventory reset that entailed companies filing \u201cdeclarations\u201d of their active production or import of chemicals.\u00a0 That failed to get any Republican support.\u00a0 Now some are dismissing the Inventory reset provisions of the Senate\u2019s Lautenberg Act, <a href=\"https:\/\/www.congress.gov\/bill\/114th-congress\/senate-bill\/697\">S. 697<\/a>, as mere window-dressing\u00a0or even an industry-friendly provision.\u00a0 (The House TSCA reform bill, <a href=\"https:\/\/www.congress.gov\/bill\/114th-congress\/house-bill\/2576\">H.R. 2576<\/a>, has no analogous provision.)<\/p>\n<p>As TSCA reform efforts advance, huge debates have swirled around how long it will take EPA to scrutinize chemicals in use, what resources will be needed, etc.\u00a0 These questions cannot be answered with any confidence at this point \u2013 because we simply don\u2019t know how many chemicals are in use.\u00a0 An essential first step under a reformed TSCA is to reset the TSCA Inventory and establish a new baseline.<\/p>\n<p>Another key advantage of an inventory reset is the opportunity it provides to reexamine past confidentiality claims that have masked the identities of some 17,000 of the 85,000 chemicals on the Inventory.\u00a0 S. 697 couples companies\u2019 declarations of active production or import with a requirement that they reassert any chemical identity CBI claims they wish to maintain.\u00a0 (You can\u2019t require reassertion of claims for chemicals no one is making anymore.) \u00a0EPA then is mandated to review and require substantiation of all such claims within 5 years.<\/p>\n<p>We simply have to reset the TSCA Inventory so that we understand just how big the task ahead is.\u00a0 Not to do so would be to bury one\u2019s head in the sand.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Richard Denison, Ph.D.,\u00a0is a Lead Senior Scientist. No one knows how many chemicals are in use today.\u00a0 It\u2019s a problem that we don\u2019t. The TSCA Inventory lists about 85,000 chemicals, but because it is a cumulative list that started in 1979, it lists all chemicals that have been in commerce at some point since then.\u00a0 &#8230;<\/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":[56107,56109],"coauthors":[],"class_list":["post-4472","post","type-post","status-publish","format-standard","hentry","category-policy","category-tsca","tag-lautenberg-act","tag-tsca-modernization-act"],"acf":[],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/4472","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=4472"}],"version-history":[{"count":1,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/4472\/revisions"}],"predecessor-version":[{"id":12746,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/4472\/revisions\/12746"}],"wp:attachment":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media?parent=4472"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/categories?post=4472"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/tags?post=4472"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/coauthors?post=4472"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}