Bill Greggs Testimony at Congressional Hearing on TSCA Chemical Control

This is a continuation of my series taking a closer look at the November 17, 2009 Congressional hearings on "Prioritizing Chemicals for Safety Determination." Earlier I gave an overall summary. Today I look at the testimony of William (Bill) Greggs, who is now a private Chemical and Environmental Policy Consultant but for 37 years was a chemical engineer and global chemical policy expert with the Procter & Gamble Company. Greggs was testifying on behalf of three processor and user organizations, namely the Consumer Specialty Products Association (CSPA), the Grocery Manufacturers Association (GMA), and the Soap and Detergent Association (SDA).

Greggs noted that "CSPA, GMA and SDA are committed to manufacturing and marketing safe and innovative products." He emphasized that the organizations agree that TSCA needs to be modernized and that it is critical that there be "development of a mechanism by which EPA will prioritize existing chemicals for review and assessment." He believes that "a priority setting process developed by Congress must be risk-based, taking into account both a chemical's hazards and potential exposures. Chemicals identified as the high priorities should be those substances with both the highest hazards and the highest potential exposures." (emphasis in original)

He noted that the three organizations have "collaborated with various industry representatives on the development of a risk-based and efficient tool that EPA can use to prioritize chemical substances." They recommend a framework that accounts for increasing levels of hazard on one axis and increasing levels of exposure on the other axis. On the hazard axis the criteria could include whether the substance was a carcinogen, mutagen or reproductive toxicant (CMR) or persistent, bioaccumulative and toxic (PBT), as well as others. For exposure axis the indicators could include the use pattern of the chemical, its biomonitoring findings (e.g., the CDC data), industrial releases as reported through the Toxics Release Inventory (TRI), and whether the chemical is found in water or the air.

The belief is that this process would identify the chemicals with greatest potential risk for prioritized review. Greggs asserted that stakeholders must be allowed to review and comment on the draft assessments, and that they must be given the opportunity to "provide additional information enabling a more informed decision or to remedy erroneous results of the priority setting process." He noted that "this is a critical component Congress must include that will significantly improve the results of this very important exercise."

Greggs felt that "done properly, this priority setting process would rank all chemicals from highest to lowest in a relatively short period of time." He noted that "the complete priority setting process will take EPA some time to accomplish," and therefore he encouraged Congress "to develop an additional mechanism that will enable EPA to identify the chemicals of highest priority for immediate assessment." To accomplish this, he recommended a process "that would require EPA to screen the data from the most recent Inventory Update Rule (IUR) submissions to identify chemicals that have the highest hazards and highest potential exposures. (emphasis in original) Through this process he believes "EPA could identify 50 to 100 chemicals that could quickly move into EPA's safety assessment process while the Agency works on prioritizing the remaining chemicals in commerce" using the tool described above.

Tomorrow I will take a look at the testimony of Beth Bosley, a consultant for the Society of Chemical Manufacturers and Affiliates (SOCMA).