{"id":997,"date":"2010-11-02T11:35:25","date_gmt":"2010-11-02T16:35:25","guid":{"rendered":"http:\/\/blogs.edf.org\/nanotechnology\/?p=997"},"modified":"2024-02-12T11:01:06","modified_gmt":"2024-02-12T16:01:06","slug":"reporting-deferred-is-right-to-know-denied-acc-seeks-major-delays-in-epa-chemical-reporting-program","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2010\/11\/02\/reporting-deferred-is-right-to-know-denied-acc-seeks-major-delays-in-epa-chemical-reporting-program\/","title":{"rendered":"Reporting deferred is right-to-know denied: ACC seeks major delays in EPA chemical reporting program"},"content":{"rendered":"

Richard Denison, Ph.D.<\/em>, is a Senior Scientist. Allison Tracy is a Chemicals Policy Fellow.<\/em><\/p>\n

Well, in its comments on EPA’s proposed rule<\/a> to enhance chemical information reporting under the TSCA Inventory Update Rule (IUR), it took the American Chemistry Council (ACC)<\/a> all of 5 paragraphs to get through the lip service it no doubt felt it had to pay to supporting EPA’s proposals “in principle,” and then proceed to devote 31 pages to arguments opposing virtually every element of EPA’s proposals.<\/p>\n

Cunningly on its part, ACC’s arguments often do not oppose outright the EPA proposals.\u00a0 Rather, it seeks to put off their implementation for as long as possible.\u00a0 EPA’s proposed rule calls for reporting in 2011 that would provide information for years 2006 and forward.\u00a0 In contrast, ACC would have EPA put off implementation of all<\/em> of its proposed IUR enhancements, with the result that both EPA and the public would not get any of the additional information until at least 2015.<\/p>\n

Like we said in the title of this post:\u00a0 Reporting deferred is right-to-know denied.<\/p>\n

We’ll be posting more about ACC’s comments in the coming weeks, but in this post, we’ll consider the core argument ACC makes for deferral:\u00a0 that “the business of chemistry is product-focused, not substance focused.”\u00a0 ACC would have us believe their member companies don’t know what chemicals are in any of the products (i.e., mixtures of chemicals) they make and sell.<\/p>\n

This argument warrants \u2013 ahem \u2013 additional scrutiny.\u00a0 <\/p>\n

Of course, it is only through chemical substance-specific information that EPA is able to make informed judgments, assessments and decisions about chemicals in commerce. \u00a0That’s why the Toxic Substances Control Act (TSCA) of 1976 is and has always been chemical substance-specific.<\/p>\n

If this proposed TSCA rule were the first time in the history of the universe that EPA had sought chemical-specific information from industry, one might have some sympathy for this argument.\u00a0 But consider the following:<\/p>\n