[NOTE: See the Update at the end]
Two of the largest chemical trade associations recently sponsored the chemical industry trade show called GlobalChem. Among the many industry, consultant, and government speakers was Dr. Richard Denison of the Environmental Defense Fund (EDF). Dr. Denison took the opportunity in his talk to highlight where the EDF-sponsored advocacy coalition, Safer Chemicals Healthy Families, differs from industry in the nuts and bolts of TSCA reform.
Denison first noted that 5 years after the deadline for completion of the voluntary HPV Challenge there are still only 60% of chemicals with final submissions. Not a great track record for self-policing in his opinion. He then listed three major differences between what the SCHF Coalition wants and what he characterizes industry to want.
1) SCHF wants data on all chemicals, while industry wants only to provide data on the small subset of chemicals that are of high priority. Industry believes that a REACH-like data call-in for all of the 85,000 chemicals on the current TSCA Inventory is overly burdensome, impossible to manage, and not very productive. Denison believes that data on all chemicals must be obtained so that safe chemicals can be identified for use as substitutes, otherwise you could identify a problem chemical that needs to be banned but have no data on the safety of potential replacements.
2) SCHF wants prompt action on the "most dangerous" chemicals such as those with high hazard, high exposure, PBTs, and those that have already been identified as of higher concern through other programs, while industry wants a long, costly risk assessment process that prolongs study before taking action.
3) SCHF wants to consider multiple sources of exposure, consistent with the recent NAS recommendations, while industry wants to assume that humans and the environment are only exposed to one chemical at a time. Here there is the logistical problem of just how one might go about determining hazard of mixtures but also of determining exposure not only of one chemical from multiple sources but many similar-acting chemicals from multiple sources.
I suppose one could take exception to whether Denison accurately characterized the industry positions, but at the very least it seems he is close enough for argument. There are very real concerns from industry of the burden of a REACH-like program that requires vast resources, both from industry and EPA (REACH created an entirely new 400-person and growing Agency to deal with the data review). There are also very real concerns that without having data for alternative chemicals there is no way of knowing that they are actually "safer" substitutes for obviously hazardous materials. And if there is no exposure, there is no risk, no matter how hazardous a chemical might inherently be. So an accurate assessment is no easy task.
Clearly there is still a lot of work to be done. Hopefully the expected introduction of the Kid Safe Act will give a concrete proposal on which all stakeholders can then base a dialogue. I think that without an actual bill we will simply be dancing around the edges and not getting into the vast differences in the details.
Update: Note that Richard Denison, the subject of this post, has provided additional information in the comment below, including what he calls “the democratization of chemicals management.” Please click on the Comments link below.
2 comments:
Thanks, Dake, for this great summary post on what we see as some of the key differences in positions going into the next phase of the TSCA reform debate.
I want to provide a reason in addition to the one you noted as to why we need comprehensive hazard, use and exposure data for chemicals in commerce, one that speaks to the capacity issue you raise: My view is that EPA cannot do the job of assessing and managing so may chemicals all by itself: We need all other actors who make decisions about chemicals—including state governments, companies and institutions that use, buy, sell and make chemical products, and academic researchers—to have access to robust information on which to base those decisions. That’s something I have termed “the democratization of chemicals management.”
The Safer Chemicals coalition, of which EDF is but one of more than 200 members, has elaborated on each of these key differences on the coalition’s website, www.saferchemicals.org.
Thanks for the additional information, Richard.
Resources are definitely going to be a consideration in the new legislation. EPA never seems to have enough, industry is spread pretty thin with REACH et al., and NGOs like yours only have so many man-hours to deal with the myriad of health and environmental issues that impact the lives of all of us. Clearly we need to focus on those activities that give the greatest bang for the buck (monetarily, temporally, and health and safety wise).
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