ECHA Issues "Last Call" for Chemical Classification and Labeling Notifications

Have you notified your substance under the EU's Classification, Labeling and Packaging regulation (CLP)?  ECHA has issued a "last call" to companies who need to notify by the January 3, 2011 deadline.  All manufacturers and importers of substances that "are hazardous" according to the CLP regulation must notify the correct classification and labeling (C&L).  They also need to prepare updated safety data sheets (SDS) to reflect the new classification and labeling requirements.

For those companies who registered their chemicals under the first REACH registration deadline of November 3, 2010, they have already complied with the CLP and do not have to notify separately (assuming, of course, that they properly reported C&L in their REACH dossiers and have passed all the completeness, business rules, and financial checks).

The January 3, 2011 deadline is especially important for companies who manufacture or import dangerous chemicals at tonnages that do not require registration until 2013 or 2018.  That is because the C&L notification must be completed now, even though their registrations won't be due for up to several years.

For anyone still needing to notify, the REACH-IT system will remain open only between the hours of 10 am and 7 pm GMT (check your local time zone equivalent) from December 27 through 30, 2010.  It then will reopen for the last 24 hours on the last submission day (Monday, January 3, 2011).

More explanations of the classification and labeling notification requirements, along with access to various notification tools, can be found on the ECHA web site.

ECHA Recommends 8 Substances of Very High Concern be Subject to Authorization

While most attention has been on meeting registration deadlines and dealing with the new classification and labeling scheme, the European Chemicals Agency (ECHA) has also been busy at work assessing substances of very high concern (SVHC).  Yesterday ECHA recommended the addition of 8 chemicals to the candidate list for inclusion in the authorization annex based on carcinogenicity and/or reproductive toxicity issues.
The eight substances are:

• Diisobutyl phthalate – DIBP (toxic to reproduction). A substance used as plasticiser for nitrocellulose, polyacrylate and polyacetate dispersions;
• Diarsenic trioxide – As203 (carcinogen). A substance used in the manufacture of glass with special properties and of zinc;
• Diarsenic pentaoxide – As205 (carcinogen). A substance which could be used as a replacement for diarsenic trioxide, no known current uses in the EU;
• Lead chromate (carcinogen and toxic to reproduction). A substance used as pigment and in the manufacture of pyrotechnics;
• Lead sulfochromate yellow - C.I. Pigment Yellow 34 (carcinogen and toxic to reproduction). A pigment used to colour plastics and coatings;
• Lead chromate molybdate sulphate red - C.I. Pigment Red 104 (carcinogen and toxic to reproduction). A pigment with similar uses as lead sulfochromate yellow;
• Tris(2-chloroethyl)phosphate – TCEP (toxic to reproduction). A substance used as a plasticiser and viscosity regulator with flame-retarding properties for coatings;
• 2,4-Dinitrotoluene - 2,4-DNT (carcinogen). A substance mainly used in explosives and propellants for ammunition.

The European Commission makes the final decision on the inclusion of the substances in Annex XIV of the REACH Regulation.  This now makes 46 chemicals on the candidate list waiting for addition to Annex XIV, after which they would only be eligible for continued use if manufacturers or importers applied for authorization and could show a combination of controlled use and a plan for finding substitutes.  Any authorization would be limited both temporally and with restrictions in the specific uses allowed.

More on the ECHA recommendations and the authorization process can be found on the ECHA web site.

US and Europe Agree to Share Chemical Data

Last week the USEPA, which has responsibility for managing chemicals in the US, and ECHA, which does the same in the European Union, signed a statement of intent (SOI) to share data, cooperate with each other on chemical reviews, and even exchange staff (or perhaps in this age of budget cuts, just share video-conference call links).  The SOI acknowledges all the work that ECHA and industry have done in this past few years developing a system to submit and review health and safety data under the REACH program.

According to the SOI, the scope of the planned cooperation could include:

- scientific collaboration and information exchange, in particular with regard to the registration (i.e., inventory) as well as hazard and risk assessment of chemical substances;
- exchange of operational experience as well as experience in strengthening regulatory capacities, for instance through training programmes;
- communication activities;
- active disseminaton of public information and publications related to each other’s activities;
- information exchange on matters of common interest, including emerging risks from chemical substances or guidance development; and
- sharing information and experience on risk identification, risk assessment and risk management tools and other similar products and related expertise.

Suggestions that such a SOI have been offered by both EPA and personal for the last month or two, so this shouldn't come as a surprise.  With TSCA reform in a holding pattern in the US (pending the new leadership in the House), and REACH just passing its first major data submission milestone, both groups seek to maximize the value of the data they are collecting and introduce some much needed efficiency in the chemical review process.  This is especially important now that chemicals are manufactured and traded worldwide.  Larger multinational companies and their affiliates should benefit from the likely data sharing between jurisdictions, but smaller and medium sized companies will also benefit as the costs of compliance get reduced by the economies of scale (e.g., if an assessment in Europe is accepted largely as is for the US, that would certainly save the cost of having to do essentially the same thing twice).

The SOI can be downloaded as a PDF from the EPA web site.

Disclosure of Fracking Ingredients May Become More Transparent

Fracking has been in the news a lot lately.  Especially for the questions surrounding the chemicals used in the process.  What is fracking, you ask?  In short, fracking, which is a shortened form of hydraulic fracturing, is the process by which oil and gas explorers use chemicals and fluids under pressure to force the expansion of cracks (fractures) in rocks as a means to increase the output of a well.  Recently there has been a lot of pressure (no pun intended) on oil companies to publicly reveal the chemicals used in fracking fluids.  There has been resistance to this idea, largely on confidential business information grounds, but that might be changing.

This week the primary trade association for the oil industry, the American Petroleum Institute (API), joined with other oil and gas trade associations to endorse a plan in which companies would voluntarily disclose the chemicals found in fracking fluids. The plan was developed by Groundwater Protection Council (GWPC) and the Interstate Oil and Gas Compact Commission (IOGCC).   In endorsing the plan, API noted in its press release that:

 “The states are the proper authority for determining requirements for chemical disclosure; so a program developed by the GWPC, and endorsed by the IOGCC is a step toward a solution on disclosure,” said API’s CEO, Jack Gerard. “But it is critical that we ensure confidential business information is protected and we will work with the GWPC to improve the reporting elements — which ultimately should enable maximum participation and enhance the program’s overall effectiveness.”  

The key here is that the plan, which involves development of an electronic registry, is both voluntary and based in the states rather than being federal level mandatory requirements.  One concern from the NGOs, however, is that the proposed plan could delay any actual disclosure for quite some time as the registry is developed over several years.

Either way, all sides agree that hydraulic fracturing helps to improve the amount of oil and gas that can be extracted from any given well.  That's important both from a cost-effective and efficiency point of view, but also from the understanding that the more that can be extracted from wells already drilled reduces the pressure on drilling more wells.

Washington State Moves Forward on Children's Safe Chemical Rules in Lieu of TSCA Action

I have mentioned previously here that with TSCA chemical reform trudging through Congress on the federal level, the States have continued to move forward with attempts to protect human health and the environment on a more local scale.  One of these efforts is the Children's Safe Product Act (CSPA) passed by Washington State in 2008.  While Governor Gregoire has suspended rulemaking in general because of the state of the economy, she has exempted this particular rule to continue through the development process.  The goal of the proposed law is to focus on protecting children from toxic chemicals.

According to the Department of Ecology, which manages health and safety issues in Washington, the CSPA consists of two parts:

The first part "limited the amount of lead, cadmium and phthalates allowed in children's products sold in Washington after July 1, 2009. These standards were substantially preempted when the U.S. Congress passed the Consumer Product Safety Improvement Act (CPSIA) in July, 2008. The federal Consumer Product Safety Commission will enforce this act."  So this part is essentially dormant.

"The second part of the CSPA requires Ecology, in consultation with the Department of Health, to develop a list of chemicals that manufacturers must report on. As required by the law, chemicals on the list are toxic and have either been found in children’s products or have been documented to be present in human tissue (blood, breast milk, etc.). However, the mere presence of these chemicals in children’s products does not necessarily indicate that there is a risk of exposure." 

Rules to implement this second part of the CSPA are currently open for public comment until December 31st.  These draft rule list 59 chemicals considered to be of high concern to children.  Most are familiar to people in the chemical control business as they have been targeted by other states as well as federal and international laws.  The law stipulates that the chemicals selected must be known to be toxic, commonly found in products used by children, are used in home environments, and found in biomonitoring of human blood and tissue samples. 

Once the final rules are issued, "manufacturers of children's products must report to Ecology if their products contain these chemicals."  These notifications will be required by law on a particular schedule, but the CSPA does not stipulate what happens once they are notified.  Presumably the state is interested in collecting data on what chemicals, and in what volumes, are used in the state so they can take any needed action.

Inspector General Inquires into EPA's Voluntary Children's Chemical Evaluation Program

The Voluntary Children’s Chemical Evaluation Program (VCCEP), which advocacy groups had criticized for years as ineffective and a "stall" by industry, was halted by the Obama administration.  Now it seems EPA’s Inspector General (IG) has launched an inquiry into the program because EPA has indicated it intends to model other programs on VCCEP.  The IG says it will determine “whether there are alternative mechanisms for achieving children’s health protection goals from chemical exposure.”

VCCEP was a product of the 1998 Chemical Right to Know Initiative, "the goal of which was to give citizens information on the effects of chemicals to enable them to make wise choices in the home and marketplace."  VCCEP itself was launched in December of 2000, and for many years was a focal point for EPA to work with industry to assess the potential effects of 23 chemicals on children's health.  Of the 23, only 20 were actually sponsored, with the chemicals selected being some for which children had a high likelihood of exposure. The intent was to have companies that manufactured or imported these chemicals to volunteer to provide information on health effects, exposure, risk, and data needs. Thirty-five companies in 10 consortia responded.

Unfortunately, 10 years after it was initiated the program seems to have not gotten past its initial pilot program.  Like the voluntary High Production Volume Chemical Challenge, the voluntary nature of the program resulted in actual participation dropping off as soon as the program fell out of the public's field of view.

The goal of the IG review is to learn from this experience before EPA initiates a new effort to assess the effects of chemicals on children's health.  Given the slow movement of TSCA reform in Congress, and the change in power structure for the next two years leading into a presidential election, EPA and others are looking for ways to carry on their mandate to protect public health, especially that of children.

More information can be found on the VCCEP program web site.

AGU Fall Meeting Attracts Nearly 20,000 Scientists

It's December and if you're in San Francisco you might be one of the nearly 20,000 scientists attending the annual fall meeting of the American Geophysical Union, the worldwide scientific organization of mostly earth and space scientists (aka geoscientists).  From December 13-17th they will gather to present - and listen to - over 18,000 platform and poster presentations on the science.  For anyone who has never been to a scientific meeting before, this is what science is about when you get out of your lab or field site.  Knowledge.

With the Cancun climate meetings just wrapping up, the AGU meeting is guaranteed to have many animated discussions about science related to climate.  Scientists will find out what others have been working on, argue with each other in the hallways, and yes, laugh about the good old days back in the stone ages.

As big as this meeting is (and it's not even the biggest scientific meeting), only about a third of the worldwide membership will be able to attend.  According to its web site, "AGU membership encompasses more than 58,000 individuals from over 135 countries."  The goal of membership "is to unite Earth, atmospheric, oceanic, hydrologic, space, and planetary scientists by providing a dynamic forum for the geophysical community through scientific journals, meetings, electronic mail, a weekly newspaper, scientific and technical committee activities, and several online data and information services."

In other words, a way to share information about new discoveries, new data, and potential areas of further research.

Information about the fall meeting can be found here.  A PDF of the program book can be downloaded here (warning: it's 123 MB so takes a while to download).

ECHA Lets You Search REACH-Registered Substances - Is Your Chemical Legal?

November 30th has passed and (hopefully) all of the chemical substances pre-registered at manufacture or import above 1000 tonnes per year have now been registered (if not, realize that you cannot be manufacturing or importing them in Europe).  Now ECHA has made available a searchable database of information on registered substances. According to ECHA, 

The information in the database was provided by companies in their registration dossiers. You can find a variety of information on the substances which companies manufacture or import: their hazardous properties, their classification and labelling and how to use the substances safely, for example. 

In total (as of earlier this week), there had been 19,182 REACH registrations and over 1.4 million classification and labeling notifications.  Classification and labeling for substances must now be done in Europe in accordance with the new Classification, Labeling and Packaging Regulation (CLP), which implements the globally harmonized system (GHS) of classification and labeling the EU (needless to say "globally harmonized is more than a little bit of a misnomer given it is hardly harmonized globally).

US House Names Key Committee Chairs Affecting Climate Change Regulation

With the Republican party becoming the majority in the US House of Representatives in last month's election, that means there will be new chair people for the key committees and subcommittees.  The biggest news is that Fred Upton of Michigan will take over the chairmanship of the House Energy and Commerce Committee, which is the one with oversight authority for issues such as climate change and other energy and environmental issues.  Upton beat out Joe Barton of Texas, most famously known for his apology in a House hearing to BP President Tony Hayward.

The committee also would have jurisdiction over any attempt to roll back the health care law that was passed in this Congress.  Meanwhile, Ed Whitfield of Kentucky is hoping to take over the subcommittee chairmanship that Upton held.

Other key Republican committee assignments include Darrell Issa of California to chair the Oversight and Government Reform Committee.  Issa has said that he intends to hold hearings investigating climate scientists even though all investigations have exonerated all scientists of any wrongdoing while demonstrating the tendency of climate deniers to misrepresent both the state of the science and what scientists say about it.  The scrutiny of climate science is also part of Ralph Hall's intentions as the Texas Representative takes over the House Science Committee.

All of this means that science will be on trial, or depending on your point of view, the victim of witch hunts, by the incoming Republican leadership in the House.  Meanwhile the science continues to demonstrate with greater and greater certainty that the planet is warming due to man's activities.  So it will be interesting to see in the hearings that are very likely to occur whether scientists are able to take advantage of the opportunity to educate a few Congressman.

EPA Publishes Alternative Assessment Criteria for Design for the Environment

"EPA's Design for the Environment (DfE) works in partnership with industry, environmental groups, and academia to reduce risk to people and the environment by finding ways to prevent pollution. For more than 15 years, through partnership projects, DfE has evaluated human health and environmental concerns associated with traditional and alternative chemicals and processes in a range of industries. These analyses have empowered hundreds of businesses to select safer chemicals and technologies. DfE focuses on industries that combine the potential for chemical risk reduction with a strong motivation to make lasting, positive changes."

Recently they published an Alternative Assessment Criteria for Hazard Evaluation Document.

Short on time today, but will be back later.

ECHA Will Add 8 Chemicals to its Substances of Very High Concern List

Now that the European Chemicals Agency (ECHA) has succeeded (mostly) in handling the thousands of substance registrations due by November 30th, they will continue to look at Substances of Very High Concern (SVHCs).  To that end they will be adding eight SVHCs to its list of substances to be controlled under the Authorization part of REACH.

 

The substances are:

- Di-isobutylphthalate (DIBP)

- Diarsenic trioxide

- Diarsenic pentaoxide

- Lead chromate

- Lead sulfochromate yellow (C.I. Pigment Yellow 34)

- Lead chromate molybdate sulphate red (C.I. Pigment Red 104)

- Tris(2-chloroethyl)phosphate (TCEP)

- 2,4-dinitrotoluene (2,4-DNT)

 

But that isn't all. ECHA also has proposed another eight substances for inclusion on the candidate list, which depending on feedback from stakeholders, could also end up being added to the Authorization Annex under REACH. Those eight are:

 

- Chromium trioxide

- Acids generated from chromium trioxide and their oligomers

- Cobalt(II)sulphate

- Cobalt(II)dinitrate

- Cobalt(II)carbonate

- Cobalt(II)diacetate

- 2-methoxyethanol

- 2-ethoxyethanol

More to come.

EPA Brings to 1000 the Number of Chemicals Being Tested with ToxCast

Perhaps lost in all the attention with the REACH deadline was an announcement last week by the USEPA that ToxCast screening program has "entered a new phase," in which it will add another 700 chemicals for testing "potential toxicity to people and the environment."  About 300 chemicals, mostly pesticides, were tested in the first phase, which puts chemicals through a series of fast, automated assays to screen for possible toxicity.  The hope is that ToxCast will be able to rapidly screen the roughly 85,000 chemicals on the TSCA Inventory, as well as screen new chemicals before they are put on the market.  Those chemicals for which ToxCast suggests some concern would be put into a more comprehensive evaluation process.

More information on ToxCast can be found here.

ToxCast employs a battery of rapid assays. Rather than rely on animal testing to discern toxicity, the battery includes tests that look at such things as gene expression, real-time electronic sensing, in vitro genomics, biochemical markers, and for those that want to see actual organisms, zebra fish development.

More information on the chemicals being tested can be found here and more information on EPA's computational toxicology program is here.

Lisa Jackson Marks the 40-Year Anniversary of EPA

Forty years ago, Americans across the nation took up a call for cleaner air, safer water and unpolluted land.  They saw that to keep our families healthy, to build clean communities, and to make America stronger for the future, we needed to protect and preserve our environment.  That grassroots movement led to the creation of the U.S. Environmental Protection Agency.  At its formation, the EPA was tasked with repairing the damage already done to the environment and establishing guidelines to help Americans make their environment cleaner and safer.

That is how EPA Administrator Lisa Jackson starts off her "40th Anniversary Message" marking forty years of EPA's existence, which officially started December 2, 1970.  She goes on to say:

As we look to the past, we are also focused on the future.  The EPA is strongly committed to protecting and preserving our country's environment through taking action on climate change; improving air quality; ensuring chemical safety; cleaning up our communities; protecting America's waters; working for environmental justice; and building strong state and tribal partnerships.

The EPA has set up a whole page called EPA@40: Healthier Families. Cleaner Communities. A Stonger America.  The page highlights "40 years of achievements" (and a proclamation from President Obama).

See it all here.

The Final REACH Registration Numbers Are In - ECHA Reports Nearly 25,000 Registrations

Yesterday (November 30, 2010) marked the first deadline for registration of chemicals under the European Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program.  And the European Chemicals Agency (ECHA) has quickly issued a press release summarizing the results - "ECHA had received 24,675 registration dossiers, submitted for nearly 3,400 phase-in substances."

While companies have had almost 3 years to prepare dossiers on their chemicals, most of that time was spent working with other companies in consortia and navigating the new idea of SIEFs (Substance Information Exchange Forums).  According to ECHA:

T"the numbers of registrations increased steadily throughout the year, but from September 2010, the trend changed. Numbers soared dramatically - incoming registrations in a single month totalled four times the number of dossiers previously registered. The increase became more gradual again in October – an increase of 7% percent - with statistics increasing again over the last month."



About 12% of dossiers were submitted by "Lead Registrants," i.e., the company who volunteered to present the data developed by consortia and other groups of companies manufacturing or importing the same chemicals.  About 82% of the submissions were from "Member Registrants," those companies who contributed to consortium development of the dossier submitted by the Lead.  Only 6% of the submissions were from individual registrants, i.e., single companies that provided all the data for a chemical.


Nearly a quarter of submissions came from one country - Germany - which shouldn't be too surprising given the number of larger firms located there.  Most of the submissions (86%) came from large companies, with medium, small, and micro sized companies accounting for only 9%, 4%, and 1% of the submissions, respectively.


Only 580 of the nearly 25,000 dossiers contained testing proposals, for a total of 1,548 proposed tests.  ECHA will review all of these and any test proposed on animals will be subject to public consultation.



More details can be found in the ECHA press memo and registration statistics.

As Europe Bans BPA in Baby Bottles, USEPA Works with BPA Manufacturers in Design for the Enviroment

Bisphenol-A, more commonly known as BPA, has gotten a lot of attention lately.  As noted last week, the EU has voted to ban BPA from baby bottles beginning in March 2011, and not long ago Canada declared BPA to be CEPA-toxic.  Meanwhile in the USA the Environmental Protection Agency is following through on at least some of the provisions of its Chemical Action Plan for BPA.  One of those provisions was for EPA to engage industry in its Design for the Environment program, or DfE.

Initially the DfE program is focusing on "finding safer alternatives to BPA used as a developer for dyes in thermal paper, which is often used in cash register or sales receipts."  This narrowing down into a specific use of the chemical is typical of DfE, where the goal is to examine all the ways to solve one particular identified risk area.  In the case of BPA, the DfE program officially kicked off in July 2010 and is just now compiling a list of viable BPA alternatives and alternative technologies.  The goal is to complete a draft evaluation of ecological and human health hazards and environmental fate by May of 2011, with a final report in October 2011.

According to the DfE site, "some receipts made of thermal paper may now contain as much as 10 mg of BPA, which could pose a risk for human exposure, as well as account for substantial environmental releases of BPA. The goal of this assessment is to facilitate movement towards safer alternatives used in thermal paper."

More information on the program, and a list of participating companies and their representatives, see here.  Participants include thermal paper manufacturers and converters, chemical manufacturers, retailers, trade associations, trade unions, NGOs, government representatives, green chemistry consultants, and others.  All working to find solutions for a particular identified chemical use pattern.

ECHA offers help for REACH registrants still blocked by data sharing disputes

Tomorrow (November 30) is the final day to register chemicals manufactured or imported at over 1000 tonnes per annum under the REACH regulation in Europe.  Most companies have registered their chemicals (and many are rushing to complete the process now).  But some companies are still having some problems negotiating letters of access (LOAs) with data owners for endpoints they are hoping to fulfill with read-across or other data owned by other companies.

ECHA stipulates that companies should have worked out these details long ago, but understands that there are cases where cost disputes are still raging.  So they have offered some assistance.

Until 30 November at noon (Helsinki time), companies can request ECHA's help when they cannot agree with a previous registrant on sharing the costs of data already registered. 

The goal is to allow companies "to submit a registration dossier, even if the final decision has not been taken on their data sharing complaint. This is a temporary solution to enable these potential registrants to submit dossiers while their data sharing dispute is still awaiting resolution."  But ECHA goes on to say that "in any case, these potential registrants must be able to demonstrate that they have made every effort to share the cost of submitted data in a fair, transparent and non discriminatory way and that the other party did not make such efforts."

If your company is facing this problem, you are still responsible for registering your substance.  Contact ECHA immediately.

More more information, see the ECHA web site.

ECHA Will Charge a Fee if You Said You Were an SME (REACH Rhymes)

The European Chemical Agency (ECHA) has issued a notice that it will charge an administrative fee to those companies who wrongly claimed to be a small or medium sized enterprise (SME). Apparently quite a few companies have claimed that they were smaller than they actually are, either through misunderstanding of how to calculate their size or through an attempt to benefit from reduced registration fees for smaller entities.  According to ECHA:

"As from 1 December 2010, ECHA will collect an administrative charge from registrants who wrongly claimed to be entitled to a fee reduction or a fee waiver. If ECHA concludes that the size of a company is larger than registered under REACH, the company will not only have to pay the difference in registration fee but also an administrative charge as follows (all values in Euros):"

Size of company	Administrative charges
Large (non-SME)	20 700
Medium	14 500
Small	8 300
Micro (*)	2 070

(*) Refers to fee waivers only

Also according to ECHA, with only a few days left to the November 30th registration deadline, over 16,000 registration dossiers have been received.  This is less than ECHA anticipated, which means either there will be a large proportion registering at the last minute or a lot of chemicals will not meet the statutory deadline.  The latter means that companies would not be able to continue production until they submit and pass all the completeness checks for their dossiers.

EU Moves to Ban BPA from Baby Bottles

This week the European Commission's Standing Committee on the Food Chain and Animal Health moved to ban the use of bisphenol A (BPA) in baby bottles beginning next spring.  BPA is an organic chemical used to make polycarbonate plastics like those in baby bottles and thousands of other plastic products.  It has come under attack as a possible endocrine disruptor, which "can mimic the body's own hormones and may lead to negative health effects."

That said, various government and regulatory bodies around the world have defined "safe levels" for humans, though new studies have raised new concerns about whether those levels truly are safe.  The problem is that effects are much more subtle and hard to define, and tests to measure (and then understand the significance of) potential endocrine disruption are still being developed.  Still, last year The Endocrine Society issued a position statement on endocrine disrupting chemicals.


Responses from the EU plastics industry and health advocacy groups was as one might expect.  Industry feels that the decision goes against the totality of the scientific evidence.  Health NGOs believe the EU action doesn't go far enough as it doesn't address other uses of BPA that also may lead to infant and child exposures.

In any case, the Commission's decision will lead to a Directive to prohibit the manufacture of BPA infant bottles by March 1, 2011 and prohibit the placing on the market and import of BPA infant bottles after June 1, 2011.  Member States have until February 15th to develop national level regulations to implement the Directive.

EPA Goes After "Endocrine Disrupting Chemicals"

In 1996 Congress passed the Food Quality Protection Act and the Safe Drinking Water Act Amendments, both of which included a provision requiring that EPA screen pesticide chemicals for their potential to produce effects similar to those produced by the female hormones.  The two laws gave EPA the authority to screen certain other chemicals and to include other endocrine effects. In fact, the two laws mandated action.

Fast forward to 14 years later and EPA is way behind on any effort to follow through on those mandates.  In large part this is because the technology for measuring endocrine effects just wasn't there back then (and some argue still is not there).  Throw in some political reticence to adding more regulatory burden to industry and you have a situation where action has been slow to come. 

But now EPA seems to have stepped up the activity level and has just issued its Second List of Chemicals for Tier 1 Screening. This list "includes 134 chemicals and substances that have been listed as priorities within EPA’s drinking water and pesticides programs."   It follows on the heels of "the initial list of chemicals to be screened for their potential effects on the endocrine system," which was released on April 15, 2009 and "the first test orders were issued on October 29, 2009."

Find out more about the endocrine disruptor testing program on the EPA site, including the status of test orders and EPA's policies and procedures.

No TSCA Chemical Reform This Year - What About Next Year?

The TSCA reform proposals put forth in bills by the Democratically controlled House and Senate in 2010 are now in the "didn't get to it" bin for the few weeks left in the current Congressional session.  In January the current minority party becomes the majority in the House, and closes the gap in the Senate.  So the question on everyone's mind (well, everyone that is a stakeholder interested in reform/modernization of the 34-year old TSCA law) is "What will happen in 2011?"

Or maybe 2012?

Because of the way Congress works any TSCA reform bills will need to be reintroduced in the next Congress before any action can be taken.  The House bill was introduced this past year by Democrats Henry Waxman and Bobby Rush, both of whom won reelection but will no longer be chairing the full committee and subcommittee, respectively, responsible for shepherding the law through the House.  As of this writing the Republican party had not yet determined who would take over the chairmanships of the key committee, but the contenders have been fairly public about their priorities and TSCA reform isn't necessarily at the top of their list.  The Senate will remain in Democratic control, though perhaps with a bit less leeway than this past Congress.  Senator Lautenberg has been passionate about TSCA reform (Kid Safe Chemical Act/Safe Chemical Act), but health and age may (or may not) limit his future influence.

Industry remains dedicated to modernizing TSCA, in large part because one federal law is easier to handle than 50 (or more) state, regional, and local laws.  With a likely more industry-friendly chairmanship in the House, this might be a good opportunity to get a new law passed that will keep what industry considers to be "what works" of the old law while enhancing protections for human health and the environment.  But different industry groups differ on how to go about doing that.

The advocacy community remains adamant that TSCA is outdated, and in fact never really worked well at all from a health protection point of view.  They continue to push for a new law, both through renewed activism at the state level and by putting pressure on industry to come up with "concrete proposals" for a revised law.

As is normal for situations in which party control of one or both houses of Congress changes, there will be time needed to "staff up" the committees, "feel out" the likelihood of compromise by various stakeholders, and "learn something" from ongoing international activities like the Canadian chemical management plan and Europe's REACH registration.  So we should expect not to see much overt action for at least the first six to 10 months of this next Congress (though there may be some behind the scenes wrangling going on).  That suggests that TSCA reform bills might not hit the floor until late 2011 or even into 2012.  That said, with a likely contentious presidential election year going on in 2012, there are concerns among many that TSCA reform might be a priority for a future time.

EPA (Almost) Ready to Release New Chemical Action Plans

Well, in the broad definition of the word "almost."  EPA has been promising release of two new chemical action plans - siloxanes and diisocyanates - for quite some time now, but internal discussions and external input from manufacturers and users have kept EPA from finalizing them.  Still, key EPA directors have indicated they plan to put them online by the end of the year.

Beyond that EPA is still trying to decide how to proceed.  With TSCA reform not being passed this year and some uncertainty about the potential timing and/or outcome of reintroduction next year, EPA has indicated that it will continue to push the envelope on its authority under the existing TSCA law.  On the other hand, several members of the incoming majority in the House (and the closer minority in the Senate) have indicated that they think EPA has overstepped that authority in the issuance of these action plans.  So I suspect EPA is working through the options for moving forward, either with or without TSCA reform.

And as I reported yesterday, the individual states are not sitting around idly waiting for Congress to pass a new law.

With Uncertainty About the Future of TSCA Chemical Reform in Congress , States Increase Regulatory Action

I have spent a lot of time on this site talking about various aspects of the attempts to reform/update/modernize the 34-year old Toxic Substances Control Act.  One aspect I've mentioned several times is the work of various states to "fill in the gaps" of the federal level law.  A new report shows that states have stepped up their activity in light of the lack of substantive movement on TSCA reform legislation in the US Congress.

The report, by two health advocacy coalitions - SAFER States and Safer Chemicals Healthy Families - is called "Healthy States" and documents that "states aren’t waiting for Congress to take action on toxic chemicals—they are taking matters into their own hands."

According to the report, "state restrictions on toxic chemicals are on the rise, and will probably continue to increase until Congress overhauls failing federal legislation."  Among other activities, the report highlights:

• In the last eight years, eighteen states have passed 71 chemical safety laws.
• The pace of state policy making on chemicals has more than tripled in eight years.
• Sixty-six laws banned bisphenol A (BPA) in baby and toddler products (with 98% support), phased out toxic flame retardants (PBDEs) in home products (93%), reduced children’s exposure from common products containing lead (88%) and cadmium (86%), and promoted green cleaning.
• State legislators strongly supported recent state laws that create new programs for broad regulation of toxic chemicals. This includes comprehensive laws passed in California, Maine, Minnesota and Washington state.

According to SAFER States, "while Washington DC is stuck in chemical industry politics, the states are growing frustrated and taking matters into their own hands -- passing laws which will help to temper the public outcry until a day comes when we are comfortable with the chemicals that are infiltrating every part of our lives."

The chemical industry has in the past supported the concept (though not necessarily the details) of federal-level TSCA modernization, in large part because they don't want the kind of patchwork regulatory quilt in which state-level regulations would result.  With the 2010 Safe Chemicals Act bills left to die without action, new versions of the bills will need to be introduced in the next Congress.  The change of majority party in the House and the subsequent differences in viewpoint between many key incoming House members and the opposite majority party in the Senate have created some uncertainty about the path forward.  What this report shows is that the states will continue, and likely increase, their state-level action in an effort to 1) deal with the lack of federal-level action in Congress, and 2) stimulate federal-level action in Congress.

The report can be downloaded on either of the two advocacy sites linked above.  A PDF is available here.

A Rational Discussion of Climate Change - Live on C-SPAN3 [Upated with Replay]

As I mentioned yesterday there is a House hearing going on today called "A Rational Discussion of Climate Change."  You can watch it on C-SPAN3 as I write this.  I'll follow up on this after the hearing.

See yesterday for more information and links.

Here is an interesting replay of a live commenting feed from the hearing.  A lot of running commentary during the hearing (sponsored by the online version of Science magazine) by such people as Gavin Schmidt (RealClimate), Joe Romm (Climate Progress), and a variety of others who signed into the feed.  Very interesting commentary.

A Rational Discussion of Climate Change - House Hearing on November 17, 2010

Congress is back in session, and at least one Democratic committee chair is ready for a hearing called "A Rational Discussion of Climate Change: the Science, the Evidence, the Response."  The hearing will be held in the Rayburn House Office Building, Room 2325, from 10:30 am to 12:30 pm, Wednesday, November 17, 2010. It will be interesting to see how rational it is given the lame duck status of Congress.  But the line up of witnesses bears promise as they are mostly prominent scientists and other authorities testifying, mostly on the status of the science and impacts of not taking action.

Witnesses include:

Dr. Ralph Cicerone, President of the National Academy of Sciences

Dr. Heidi Cullen, CEO and Director of Communications at Climate Central

Dr. Gerald Meehl, Senior Scientist in the Climate and Global Dynamics Division at the National Center for Atmospheric Research

Dr. Richard Lindzen, Alfred P. Sloan Professor of Meteorology in the Department of Earth, Atmospheric, and Planetary Sciences at Massachusetts Institute of Technology

Dr. Benjamin Santer, Atmospheric Scientist in the Program for Climate Model Diagnosis and Intercomparison at the Lawrence Livermore National Laboratory

Dr. Richard Alley, Evan Pugh Professor in the Department of Geosciences and an Associate of the Earth and Environmental Systems Institute at Pennsylvania State University

Dr. Richard Feely, Senior Scientist at the Pacific Marine Environment Laboratory of the National Oceanic and Atmospheric Administration (NOAA)

Rear Admiral David Titley, Oceanographer and Navigator for the United States Department of the Navy, Department of Defense

Mr. James Lopez, Senior Advisor to the Deputy Secretary at the Department of Housing and Urban Development

Mr. William Geer, Director of the Center for Western Lands for the Theodore Roosevelt Conservation Partnership

Dr. Judith Curry, Chair of the School of Earth and Atmospheric Sciences at Georgia Institute of Technology

Their written remarks should be posted on the committee web site above once they give testimony.  The committee has already released a PDF of the hearing charter, which summarizes the topics each witness will address.  It also provides some useful background on the state of climate science that I highly recommend everyone read.

Oil will run out 100 years before new fuels are developed

Wondering what to get your kids for Christmas?  How about a science kit so they can develop a new fuel to replace petroleum.  A new study suggests it could make them rich.

Okay, so your kids probably aren't going to discover some new fuel source (or will they?).  But a new study reported in that great science source (Yahoo! News) suggests that we better get started looking for a new source, because we're going to run out of oil long before we find something to replace it.

If the world's oil reserves were the 1.332 trillion barrels they were estimated to be in 2008 and oil consumption was some 85.22 million barrels a day and growing at 1.3 percent a year, oil would be depleted by 2041, says the study published online last week in Environmental Science and Technology.

Then researchers from the University of California at Davis analyzed share prices of 25 oil companies and determined (to no one's surprise) that much more money is put into the conventional energy markets than to renewable or alternative energy markets.  They then "used advanced pricing equations" and calculated that "there would not be a widely available replacement for oil-based fuels before 2140, which, even if the more optimistic date of 2054 for oil depletion is retained."  All of this means that "there could be a nearly 90-year gap when it might be difficult to run a motor vehicle."

The Yahoo! article can be read here.  The original study can be found in the journal, ES&T, is published by the American Chemical Society.

More Than 1/2 Million Chemical Classification Notifications Received by ECHA

Along with REACH registrations, companies in Europe must notify all their chemicals under the new "European Regulation on Classification, Labelling and Packaging of chemical substances and mixtures" (CLP). The CLP is how the United Nations’ Globally Harmonised System (UN GHS) for classifying and labelling chemicals is being implemented in Europe.  Companies must notify by January 3, 2011, and as of now more than 500,000 notifications have been received by ECHA.

Companies who must register their substances by the fast approaching November 30, 2010  REACH registration deadline will also include CLP classifications, and this meets the obligation to notify.  However, those companies who make substances at lower tonnages and have 2013 or 2018 REACH registration deadlines must still notify under the CLP by January 3, 2011.  In short, "if you are a manufacturer or importer, you must notify hazardous substances that you place on the market on their own or contained in hazardous mixtures above certain applicable concentration limits, regardless of the annual tonnage manufactured or imported, as well as substances subject to registration under REACH and that you place on the market, to the Classification & Labelling Inventory established at the Agency."

More information on the CLP and the upcoming deadlines can be found on the ECHA web site.

ChemCon Americas Conference Debates REACH, TSCA Reform, GHS

This past week has been the ChemCon Americas conference in Philadelphia, where mostly industry representatives, regulatory experts, and scientists get together to discuss important issues affecting the chemical industry.  And this week was no exception.  Hot topics included the scramble to make the November 30th REACH deadline, the confusion over how various countries are implementing (or not implementing) GHS, and the uncertainty over what may or may not happen with TSCA reform in the United States.

Representatives from EPA continued to make the case that the 34-year old Toxic Substances Control Act just does not give them the authority to efficiently review tens of thousands of existing chemicals grandfathered onto the TSCA Inventory (for later review). With the chairmanships of the House set to switch from the Democratic Waxman and Rush to "Republicans to be named later," there still seems to be the belief that some form of TSCA reform will happen in the next Congress.  Meanwhile, a lawyer representing industry interests reminded attendees that the individual states are pressing forward with their own versions of reform, perhaps presenting industry with an even more complicated patchwork of regulations to monitor.

REACH also received attention.  A representative from the European Chemicals Agency (ECHA) encouraged companies to keep on pushing to meet the fast approaching deadline.  Tens of thousands of registrations have been received and many more are expected in the mad rush during the next two weeks.  Oh, and then there is the CLP - Europe's version of the Globally Harmonized System for classification and labeling, for which companies must notify all of their chemicals by January 3rd (even those not scheduled for REACH registration until 2013 or 2018).  And let's not forget Turkey. And China and Japan. And New Zealand and Australia.  And cosmetics?

No wonder everyone looks a little knackered.

Canada Lists 4 Chemicals to its Schedule 1 List of Toxic Substances

While the US struggles with what to do to modernize the Toxic Substances Control Act (TSCA), Europe has been busy with the first registration phase of it's Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program and Canada is well into its Chemical Management Plan evaluating their Inventory of existing chemicals.  As part of that process Canada recently proposed to add four additional chemicals its Schedule 1 "list of toxic substances" under CEPA (the Canadian Environmental Protection Act of 1999).   

The four substances are:

Vanadium pentoxide: A naturally occurring substance in the environment, "used primarily in Canada in the manufacture of ferrovanadium and as a catalyst in the production of sulphuric acid." According to Environment Canada, "vanadium pentoxide is released to air, to water and to land, mainly through combustion of fossil fuels and wood fuels from industrial activities."  It "was identified as a high priority for assessment because of its classification as a carcinogen by national and international agencies."

Potassium bromate: A man-made substance "used primarily in Canada in industrial and commercial applications," including "as an oxidizing reagent in laboratories, in the dying of textiles, and in permanent wave neutralizing solutions in the cosmetics industry."  While it appears there is limited current reporting of use in Canada, and no reported consumer uses, the substance was listed "based principally on the weight-of-evidence assessment or classification from international or other national agencies..., the critical effect of exposure...is carcinogenicity," as well as reports of genotoxicity and "a variety of non-cancer effects."

TGOPE: A thankfully brief acronym for a long chemical name, TGOPE "is a man-made component of epoxy resin used as an adhesive or binding agent" used primarily "in the manufacture of paints, coatings designed for industrial use and certain consumer epoxy-patch adhesives." Exposure is expected to be minimal because it is it seems to have limited current manufacture in Canada (but is imported) and has limited consumer uses (mostly epoxy adhesives).  Health effects assessments have not been identified, but "in vitro experiments and weight-of-evidence assessment or classification from several other analogues...show that TGOPE may cause cancer."

Methyl eugenol: Mainly "a naturally occurring organic substance in the essential oils of several plant species," used primarily "as flavour ingredients in food and beverages and as fragrance ingredients and emollients in personal care, cosmetics and other household products." According to the Canadian assessment, "the substance may also be produced synthetically."  Exposure is "mainly from its naturally occurring presence in food and beverages with smaller contributions from the use of personal care products and citronella-based personal insect repellents."  Canada has determined "that methyl eugenol may cause cancer," and may also "be genotoxic in a range of experimental studies...Therefore, it cannot be precluded that the substance may have interacted with the genetic material."

More information on these four substances can be found here.  In addition to these four listed, there were 13 substances from "Batch 9" that were not found to meet the criteria for listing.  These can be seen here.

White House Names Two Nanotechnology Scientists as 2009 Presidential Early Career Award Winners

The White House Office of Science and Technology Policy has named two scientists from the Department of Energy’s Argonne National Laboratory as 2009 Presidential Early Career Awards for Scientists and Engineers (PECASE) winners.  According to Argonne National Labs, the PECASE awards are "the nation’s highest honor for researchers in the beginning stages of their independent research careers."  The two are materials scientist Dillon Fong and nanoscientist Elena Shevchenko, who "were selected by the for their contributions to meeting America’s scientific and technological missions and the country’s economic, energy, health and security needs."

Shevchenko heads "the NanoBio Interfaces Group in Argonne’s Center for Nanoscale Materials." Nanoparticles (also called nanoscale materials or simply nanomaterials) "are small assemblies of particular materials that have special properties."  According to Argonne National Labs, "Shevchenko’s work specifically examined how nanoparticles self-organize to form more complicated materials."

Fong "works in Argonne’s Materials Science Division, where he investigates the formation and structure of complex oxide thin films." In his research, he asks "questions like how these thin film crystals grow, and how much of this growth can we control?" And "do these materials behave when they are only a few nanometers thick?"

Read more about their achievements at the links and in the Argonne press release.  Both scientists will receive their awards later this year at the White House.

American Cleaning Institute Finds Fault with California "Safer Products" Regulations

The American Cleaning Institute (ACI; formerly the Soap and Detergent Association) has filed comments to the California Department of Toxic Substances stating that the new regulations are "bureaucratic, punitive, and adversarial."  In their press release, ACI states:

California’s proposed regulations for “safer consumer product alternatives” are bureaucratic in the extreme, resource intensive for California government and the regulated community, punitive and adversarial, according to the American Cleaning Institute. 

ACI's detailed comments (93 pages, including attachments) urge the California DTSC to work with stakeholders to address proposals in need of "significant revision" as the current proposal would not accomplish "the goals
of the state’s Green Chemistry Initiative."  ACI complained about many parts of the proposed regulations, including their overly broad scope, a "flawed" chemical prioritization process, onerous reporting requirements, and what they see as "disincentives" to the development of safer consumer productes.

The full ACI comments can be read here.

ECHA Makes Available QSAR Toolbox 2.0 to Facilitate Chemical Assessments

ECHA and OECD are making available an assessment software that they call "The Toolbox."  It is intended to that the toolbox "tools" will be used by "governments, chemical industry and other stakeholders in filling gaps in (eco)toxicity data needed for assessing the hazards of chemicals."  The Toolbox incorporates information and tools from various sources into a logical workflow, including a crucial element -  grouping chemicals into chemical categories.

The fundamental features of the Toolbox are:

1. Identification of relevant structural characteristics and potential mechanism or mode of action of a target chemical.
2. Identification of other chemicals that have the same structural characteristics and/or mechanism or mode of action.
3. Use of existing experimental data to fill the data gap(s).

According to OECD, "the goal of Phase 2 development is to ensure that the category approach to filling data gaps works uniformly for all discrete organic chemicals and for all regulatory endpoints."  It is a two year work plan which began in the 4th Quarter of 2008.  "The work plan has five thematic areas namely Information Technology, Chassis Development and Additional Functionalities, Database Compilation, (Q)SAR Library and Expert System Compilation, and Training. The implementation of the features is divided between two versions."


This Version 2.0 was released in October 2010 and Version 3.0 is planned for release in October 2012.

More information and a place to download the toolbox can be found here.

Post-Election Questions - Will EPA Step Up Action, Step Down Action, or No Changes Ahead?

Now that their has been a change in the majority party in the House (or more accurately, there will be starting when the next Congress takes their seats in January 2011), how will this effect EPA's ongoing rule-making and actions?  While we don't really know the answer to that question yet, there are a few insights we can presume.

First, despite what many suggest, EPA doesn't just get to make up regulations when they feel like it.  They are bound by, and compelled by, laws passed by Congress to regulate the release of chemicals and other environmental issues.  They are required by law to move forward, and are often sued by either - and sometimes both - sides of the issue to act (or not to act).  The recent greenhouse gas (GHG) endangerment finding wasn't something they pulled out of a hat; the Court found that EPA MUST take an endangerment stand.

Second, many programs are simply ongoing activities.  While the top of the EPA hierarchy are political appointees, the vast majority of EPA staff are career professionals who simply go to work each day and do their jobs.  So work moves forward no matter what political tug-of-war may be keeping the press busy.

That said, Congressional action, or inaction, can significantly impact EPA effectiveness.  Many in the incoming majority in the House have indicated a desire to step up oversight of EPA.  So it is likely that the EPA Administrator and other senior officials will be spending more time in hearings looking at possible overstep of EPA authority rather than the many hearings held over the last two years geared towards finding a path forward to address key issues like chemical right-to-know, children's exposure, GHG emissions and climate change. 

As I mentioned in my last post, the future of the TSCA reform law is uncertain.  All stakeholders have expressed a desire, and acknowledged the need, to modernize the 34-year old law.  But doing so will require the new Congress to focus on moving forward instead of looking toward the past.  It's unclear whether that is the case.  In the end it will probably come down to industry pushing for a new law to 1) avoid a patchwork of ever-increasing state laws and 2) put in place a manageable, i.e., doable, law that protects public health and the environment.

Future of TSCA Chemical Reform Law Uncertain After Election Results

The mid-term elections in the United States have put the future of the TSCA reform into question, for a variety of reasons:

1) The current House bill was introduced by California Representative Henry Waxman and Illinois Representative Bobby Rush, who served as chairs of the relevant committee and subcommittee, respectively. Both won reelection, but with the Republicans gaining control of the House that means Waxman and Rush will be demoted to ranking members.  While the new chairs have yet to be determined, they will be Republicans and are likely to have a different vision of how to proceed.  If they proceed at all.

2) The current bills in the House and Senate probably lean slightly more toward the environmental and health advocacy position (though they might disagree with that characterization).  With Republicans now the majority in the House the new bills, which would have to be reintroduced in the next Congress anyway, will likely lean more toward the industry position (though like the advocacy side, there is quite a bit of differences of opinion between various industry stakeholders).

3) Several potential chairs of key environmental, health, and oversight committees have indicated a desire to undertake oversight hearings. So while there were many hearings on TSCA reform during the last year or two, those hearings were on finding a path forward for reform.  The will likely be some of those as well under the new chairs in the House, but the oversight committee is likely to be holding hearings on whether EPA is overstepping its current authority under TSCA as it exists now.  This could dilute the effort towards reforming the law.

There are other reasons that yesterday's election creates additional uncertainty in the continuing attempts to reform the 34-year old chemical control law, and I'll take a look at those as more information on the changed legislative dynamics in Washington becomes available.

International Scientists Sign "San Antonio Statement" Calling for Regulation of Brominated Flame Retardants

Recently a group of scientists met to discuss the growing concern about "the persistent, bioaccumulative, and toxic properties of brominated and chlorinated organic flame retardants (BFRs and CFRs, respectively) and the exposure to humans and wildlife as a result of intensive use."  The result is the “San Antonio Statement on Brominated and Chlorinated Flame Retardants.”

The signatories, nearly 150 scientists from 22 countries, are all "experts on the health effects and environmental fate of BFRs and CFRs and environmental contaminants in general. The International Panel on Chemical Pollution (IPCP), an international network of scientists working on various aspects of chemical pollution, also has approved the statement."

The San Antonio statement includes 20 points that acknowledge the scientific concern for these substances, and the fact that three brominated flame retardants have already been listed in the Stockholm Convention treaty for global elimination. They note that these materials are persistent and "can undergo long-range environmental transport."

The full San Antonio Statement in published in the online edition of Environmental Health Perspectives.  There is also an introduction to the Statement by NIEHS Director Linda Birnbaum and IPCP Board member and Professor Ake Bergman.

Director of Columbia Center for Children's Environmental Health Testifies at Toxic Chemicals Hearing

Last, but not least, of the witnesses in Tuesday's Senate subcommittee hearing on "Toxic Chemicals and Children's Environmental Health" in New Jersey, was Dr. Frederica Perera.  Dr. Perera is Director, Columbia Center for Children's Environmental Health (CCCEH), Professor of Public Health, Department of Environmental Health Sciences, Mailman School of Public Health Columbia University.  In her testimony, she focused on "endocrine disrupting chemicals and neurodevelopmental disorders, noting that an estimated 5-17% of United States children have been diagnosed with a learning or attention disorder."


She reported largely based on the work done at CCCEH, which since 1998 has "conducted international studies of cohorts of mothers and children followed from pregnancy."  Even back then, she noted, "we knew that there were ever-increasing human exposures to environmental toxicants and that rates of neurodevelopmental disorders and chronic illnesses such as childhood asthma and cancer were on the rise."  She made it clear "that these diseases had multiple causes, environmental exposures such as lead, mercury and polychlorinated biphenyls were known to contribute," but also said that it had "become evident over the previous decades that the placenta does not adequately protect the fetus from toxicants and that, due to their rapid development and immature defense systems, the developing fetus, infant and child are especially susceptible to environmental toxicants."

After sharing some of the Center's research in this area, she noted that the research demonstrates "the link between fetal and child exposures to phthalates, BPA, and PBDEs, and adverse developmental and neurodevelopment effects."  She suggested that "a preventive approach is clearly needed," and offered the example of the case of lead removal from gasoline as an illustration of the effectiveness of such an approach. She acknowledged that there were still many uncertainties in cause and effect, but suggested that:

"given the widespread exposure to chemicals such as those I have discussed, these uncertainties do not outweigh the need for a preventative approach to children’s health. The public health and economic benefits of prevention are clearly great. Our data and those of many others support a preventative chemical policy to protect our youngest and most susceptible population."

More on the hearing can be found on the subcommittee web site.