OnEarth Magazine, Wendy Gordon believes that the seemingly endless debate over BPA - the chemical used in myriad plastic bottles and other products - is a strong signal of the need for TSCA reform. She laments that "[a]fter more than 10 years of research involving hundreds of studies, government health officials according to The New York Times (September 6, 2010) "still cannot decide" whether the science is adequate to regulate BPA more strictly, an action the Food and Drug Administration has the authority to take but just won't, or can't...or would rather put off until after the next round of studies."
And herein lies a recurring problem with chemical regulation. How much data are enough? Rarely are the data so overwhelmingly clear that a particular chemical will definitely create adverse effects that the path forward is obvious to regulators, industry, and NGOs alike. Rather, the norm is that there are some data that suggest, maybe even strongly suggest, that there are concerns. But then the realities of decision-making come into play. What is the threshold of concern for taking action? Should BPA, as an example, be banned outright based on the data we have? Or should more studies be conducted to dig deeper into the specific concerns suggested by earlier studies? These are often more value judgments than clear scientific direction.
The answer is that we don't have an answer. Each case will be different as the circumstances of hazard and exposure will be different from one chemical to another and one use pattern to another. Which is why the debate seems to go on and on with no resolution. Given the significant business and personal consequences of making the wrong decision - banning something that doesn't need to be or not banning something that should be - clearly a better process is required.
Will the proposed TSCA reform bills now sitting idle in the House and Senate be that better process? It seems like it could be a moot point given the current predictions for the fall elections in the US. No matter what happens in November the bills will have to be reintroduced in the next congress and the debate will start anew. But the direction the bills take could be significantly affected by the make up of the two bodies of governance.
Or perhaps, as Wendy Gordon suggests, we will just see the continuation of "endless debate."