Industry Representatives Offer "Perspectives on TSCA Modernization"

As I've been talking about for a few days now, the chemical industry held its annual GlobalChem conference in Baltimore in the last week of March. Presentations are available at the website: GlobalChem. I reported the views of the NGO community (while Richard Denison speaks inside, a rubber duck protests outside) and the former head of the EPA toxics office (Charlie Auer). In addition, leaders for the two major chemical manufacturing trade associations, who had sponsored the conference, offered their views.

ACC President Cal Dooley reiterated his organizations guiding principles, while the new President and CEO of SOCMA, Lawrence Sloan, offered what he called a "pragmatic approach" to TSCA modernization. Inlcuded in that approach is:

1) Risk-based prioritization: All priorities should be based on risk, which considers both hazard and exposure, and not just inherent hazard. No exposure means no risk, even if the chemical is hazardous. This prioritization should be "done transparently with clear cut criteria" and decisions by EPA "should be subject to deadlines."

2) EPA should employ proven regulatory mechanisms: Sloan suggested that the "Canadian approach systematically prioritized the nation's inventory" and that the US should do the same to reset the TSCA Inventory to a workable number [note that EPA indicated it doesn't have time to reset the Inventory]. He also suggested we should learn enough from how REACH is unfolding to know that it isn't the way to go in the US.

3) Learn from ourselves: He noted that the EPA's own New Chemicals Program has provided an effective and efficient system for reviewing chemicals, "some 35,000 new chemicals since 1979," while allowing the US to lead the world in innovation.

4) Development of a new safety standard for industrial chemicals: Sloan warned of setting a safety standard that was too restrictive that could easily "black list" any chemicals listed for further study. He noted that industrial chemicals are distinctly different from pesticides, foods, and drugs, which are designed to either be highly toxic (e.g., to kill specific pests) or intentionally exposed to humans (eaten or used as medicine). In contrast, many chemicals see no direct consumer exposure.

5) Avoiding a "one-size-fits-all" approach: Again emphasizing the uniqueness of the specialty chemical sector, Sloan notes that many are small businesses engaging in batch production and not huge corporations, and thus they are "already suffering economy."

6) Adequate funding and oversight: In agreement with all speakers, Sloan emphasized that EPA needs to be adequately resourced to do the job or else it will cause a slow down in reviews and limit innovation.