Specialty chemical manufacturer and downstream user positions on the proposed TSCA reform bills introduced on April 15th were discussed in previous posts. Today the National Petrochemical & Refiners Association weighs in on the topic. NPRA represents virtually all US refiners and petrochemical manufacturers, whose members "supply consumers with a wide variety of products and services that are used daily in homes and businesses."
Like others, NPRA is concerned that the House discussion draft "significantly broadens the scope of TSCA by substantially changing the definition of 'substance' and 'mixture' to include practically any manufactured or processed good." And that makes the proposed law totally unworkable in a practical sense. NPRA is also concerned that most actions could actually be taken by EPA without the current provisions of "public notice and comment," which they say results in a lack of transparency. The draft also eliminates most opportunities for judicial review, thus potentially allowing arbitrary and unchallengeable decisions by EPA.
NPRA also feels that while there has been much emphasis on green chemistry and innovation, the "draft legislation imposes barriers to innovation that will inhibit all chemistry, including green chemistry policy and goals." They offer as an example the minimum data set requirement, which they feel will "raise the barrier of entry into the marketplace for new products as there will be a large cost imposed on companies to conduct the required testing and gather the required information for a single product." They claim that there is "an inversely proportional relationship between barriers of entry and the number of products introduced into any given market." They note that the minimum data set requirement in Europe has allowed the introduction of only 4000 new chemicals while the US introduced 18,000 in the same period.
As with the other trade associations, NPRA talks about the issues they see with prioritization, imminent hazard provisions, lack of preemption of state regulations, fees, what they see as unnecessary the emphasis on giving PBT chemicals special attention.
I'll look closer at key issues that pop up in most of the comments in future posts.
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