ECHA has announced the release of the newest version (Version 2.3) of the OECD QSAR Toolbox for use in REACH and other regulatory actions. According to their press release, "the software helps registrants and authorities to use Quantitative Structure-Activity Relationship ((Q)SAR) methodologies to group chemicals into categories and to fill data gaps by read-across, trend analysis and to assess the (eco)toxicity hazards of chemicals under REACH. This helps to reduce costs and unnecessary testing on vertebrate animals."
While many chemicals do have existing or new data to meet many endpoints, they often have data gaps. QSARs can be used both to meet some data requirements and provide an estimate of certain properties that allows decision-making on whether new testing is needed.
For more information see here.
The QSAR Toolbox and guidance documents can be downloaded here.
Science, policy, and politics. Focus on science communication and climate change. The Dake Page offers news, analysis and book reviews.
Wednesday, March 14, 2012
Tuesday, March 13, 2012
REACH Won't Work for TSCA Reform, Says Industry Based on Indiana Report
The US chemical industry is pointing to a new academic report as proof that the European REACH chemical management system is not a good fit for implementing in the US. The report from Indiana University comes while Congress has effectively punted on pursuing reform of the 35 year old Toxic Substances Control Act (TSCA).
The full report, for preparation of which the authors acknowledge receiving "unrestricted financial support from the American Chemistry Council, Dow, and DuPont," presents information about REACH and offers the following five findings:
FINDING #1: U.S. Policymakers Should Consider Simplifications of the REACH program.
FINDING #2: If a REACH-like system is adopted in the United States, more public disclosure of safety-related information and opportunities for public participation should be provided.
FINDING #3: In considering how to streamline REACH for application in the United States, more focus should be on priority-setting based on risk and the opportunity to reduce risks to human health and the environment.
FINDING #4: Since some of the frustration and burden in the early years of REACH implementation has been linked to ambiguity in program design, a REACH-like system in the United States should provide clarification about critical standards, processes, and tools.
FINDING #5: If the United States chooses to adopt a REACH-like system of registration, unnecessary burdens on industry can be lessened by allowing for mutual, cross-Atlantic recognition of registration dossiers.
The full report can be downloaded as a PDF file here.
The full report, for preparation of which the authors acknowledge receiving "unrestricted financial support from the American Chemistry Council, Dow, and DuPont," presents information about REACH and offers the following five findings:
FINDING #1: U.S. Policymakers Should Consider Simplifications of the REACH program.
FINDING #2: If a REACH-like system is adopted in the United States, more public disclosure of safety-related information and opportunities for public participation should be provided.
FINDING #3: In considering how to streamline REACH for application in the United States, more focus should be on priority-setting based on risk and the opportunity to reduce risks to human health and the environment.
FINDING #4: Since some of the frustration and burden in the early years of REACH implementation has been linked to ambiguity in program design, a REACH-like system in the United States should provide clarification about critical standards, processes, and tools.
FINDING #5: If the United States chooses to adopt a REACH-like system of registration, unnecessary burdens on industry can be lessened by allowing for mutual, cross-Atlantic recognition of registration dossiers.
The full report can be downloaded as a PDF file here.
Saturday, March 10, 2012
The Hockey Stick and the Climate Wars by Michael E. Mann - A Book Review
If you ever wanted to know how it feels to be hunted by a pack of rabid wolves, Michael Mann’s The Hockey Stick is the book for you. The “hockey stick” graph became an icon in the Climate Wars, at least in the sense that it gave a target for the climate denialist industry to focus on in their efforts to deny the science. For those who are confused the bottom line is this – the hockey stick is robust, joined by a dozen other graphs into a veritable hockey team, and represents one small piece of multiple lines of evidence that demonstrate our planet is being warmed by human activity.
Mann begins by discussing how the hockey stick was “Born in a War” during the mid-1990s. As his own research was just beginning to develop, the climate denialist industry was already hard at work attacking other scientists like Ben Santer in what Mann calls the “Serengeti strategy.” In “Climate Science Comes of Age” and “Signals in the Noise” Mann takes us through the state-of-the-science and how his emerging research relates to the research of other scientists, including future co-author Raymond Bradley. In “The Making of the Hockey Stick” Mann gives us both the history and the science that led to the seminal paper commonly referred to as MBH98 and its follow up paper MBH99. The hockey stick papers. In short, the hockey stick is merely a reconstruction of northern hemisphere temperatures going back a millennia or so and based on a range of proxy data, that is, data from corals, ice cores, tree rings and other sources of long-term information that are used to define atmospheric temperatures. This one (relatively) simple graph was the result of “a substantial body of work.”
But as the science developed so too did the attacks on that science by fossil fuel industry lobbyists and their allies. The hockey stick graph became part of the 2001 Third Assessment Report of the IPCC, and was perceived as a major threat to the denialist industry’s interests. It was actually only one of three figures used in that IPCC report showing the same sort of pattern of historical temperatures. As Mann discusses, the MBH papers didn’t even attempt to establish causality, but this fact – like most facts – didn’t seem to slow the denialist desire to set up the hockey stick as THE pedestal of climate change…and then proceed to try to tear it down.
Mann goes on in ensuing chapters to discuss the “Origins of Denial” (e.g., going back to the tobacco industry’s “doubt is our product” strategy), and the various critiques of the hockey stick. Some of the more interesting chapters have to do with the political attacks on Mann and his co-authors. The chapter “Say It Ain’t So, (Smokey) Joe!” refers to Joe Barton (“I apologize to BP” for holding them accountable for the Deepwater Horizon spill). Barton called a House hearing on the hockey stick based solely on an opinion piece written in the Wall Street Journal. Barton was universally chastised for abusing his position to carry on a political intimidation. Even other Republicans like Sherwood Boehlert and John McCain rebuked Barton’s clear attempts to harass scientists.
In “A Tale of Two Reports,” Mann relates the findings of two evaluations of the hockey stick paper – one by the National Academy of Sciences (NAS) commissioned by Sherwood Boehlert, and one by a statistics professor named Edward Wegman commissioned by Joe Barton. The NAS review was conducted by a team of highly qualified scientists and looked intensively at the research. The Wegman team consisted of Wegman, one of his graduate students, and one other co-author. The NAS review universally reaffirmed the veracity and robustness of the MBH hockey stick. The Wegman report disagreed. Not surprisingly, evidence later determined that Wegman had collaborated with denialist organizations, had passed off much of Stephen McIntyre’s faulty work as his own, and as much as 1/3 or more of the Wegman report had been plagiarized. Despite reaffirmation by the NAS, the addition of a dozen other independent reconstructions all showing the same thing, and voluminous evidence from multiple lines of investigation all showing that the hockey stick accurately represents the state-of-the-science, the denialist bloggers still repeat the false talking points coming out of Wegman’s ethically-challenged and factually-deficient report.
There is much more in the book, of course, and along the way Mann also discusses the ubiquitous inability of any denialist argument to stand up to even the most basic scientific scrutiny. He discusses the cadre of industry-sponsored blogs that serve as an echo chamber for denialist talking points, even long after they have been thoroughly debunked many times (including, for example, the falsehood that the hockey stick is broken).
Mann further discusses attempts to intimidate climate scientists in chapters called “Heads of the Hydra” (whenever one false talking point is debunked, two more false talking points are tossed out and/or recycled from the ones already debunked), “The Battle of the Bulge” (about how the denialist industry has made a last ditch effort to harass and intimidate scientists now that the science has become undeniable), and “Climategate: The Real Story” (how the denialist industry coordinated an orchestrated disinformation campaign). Mann’s recounting of how the “hide the decline” false talking point required the convenient omission of 23 words and the combining of two completely unrelated topics for the denialists to create their fake scandal is enlightening.
The final chapter “Fighting Back” is about how climate scientists have started to defend themselves and the science against the vicious harassment and intimidation of the climate denial lobby. One example he lists is Virginia Attorney General Cuccinelli’s witch hunt that was working its way up through the courts. Just this past week the Virginia Supreme Court ruled that Cuccinelli had no basis for pursuing what all parties acknowledge is nothing more than a politically motivated attempt to intimidate scientists who are doing research politicians find ideologically inconvenient.
In an Epilogue, Mann notes that his views of the “role of the scientist” have evolved over the last 10 years. Previously Mann, like most scientists, believed the role of the scientist was to do scientific research and that others should take on the duty of communicating it to the public. Now he believes that it is a responsibility of all scientists to ensure that their science is accurately communicated, and sometimes that means being out there to correct the intentional disinformation pushed by the science denial lobby. All scientists should consider this advice.
I highly recommend this book. I also highly recommend the book Global Warming and Political Intimidation by Raymond S. Bradley, the “B” of MBH98/99. Like Mann, Bradley has experienced first hand the “Serengeti Strategy” of harassment.
Photo Credit and to order the book: Amazon.com
Mann begins by discussing how the hockey stick was “Born in a War” during the mid-1990s. As his own research was just beginning to develop, the climate denialist industry was already hard at work attacking other scientists like Ben Santer in what Mann calls the “Serengeti strategy.” In “Climate Science Comes of Age” and “Signals in the Noise” Mann takes us through the state-of-the-science and how his emerging research relates to the research of other scientists, including future co-author Raymond Bradley. In “The Making of the Hockey Stick” Mann gives us both the history and the science that led to the seminal paper commonly referred to as MBH98 and its follow up paper MBH99. The hockey stick papers. In short, the hockey stick is merely a reconstruction of northern hemisphere temperatures going back a millennia or so and based on a range of proxy data, that is, data from corals, ice cores, tree rings and other sources of long-term information that are used to define atmospheric temperatures. This one (relatively) simple graph was the result of “a substantial body of work.”
But as the science developed so too did the attacks on that science by fossil fuel industry lobbyists and their allies. The hockey stick graph became part of the 2001 Third Assessment Report of the IPCC, and was perceived as a major threat to the denialist industry’s interests. It was actually only one of three figures used in that IPCC report showing the same sort of pattern of historical temperatures. As Mann discusses, the MBH papers didn’t even attempt to establish causality, but this fact – like most facts – didn’t seem to slow the denialist desire to set up the hockey stick as THE pedestal of climate change…and then proceed to try to tear it down.
Mann goes on in ensuing chapters to discuss the “Origins of Denial” (e.g., going back to the tobacco industry’s “doubt is our product” strategy), and the various critiques of the hockey stick. Some of the more interesting chapters have to do with the political attacks on Mann and his co-authors. The chapter “Say It Ain’t So, (Smokey) Joe!” refers to Joe Barton (“I apologize to BP” for holding them accountable for the Deepwater Horizon spill). Barton called a House hearing on the hockey stick based solely on an opinion piece written in the Wall Street Journal. Barton was universally chastised for abusing his position to carry on a political intimidation. Even other Republicans like Sherwood Boehlert and John McCain rebuked Barton’s clear attempts to harass scientists.
In “A Tale of Two Reports,” Mann relates the findings of two evaluations of the hockey stick paper – one by the National Academy of Sciences (NAS) commissioned by Sherwood Boehlert, and one by a statistics professor named Edward Wegman commissioned by Joe Barton. The NAS review was conducted by a team of highly qualified scientists and looked intensively at the research. The Wegman team consisted of Wegman, one of his graduate students, and one other co-author. The NAS review universally reaffirmed the veracity and robustness of the MBH hockey stick. The Wegman report disagreed. Not surprisingly, evidence later determined that Wegman had collaborated with denialist organizations, had passed off much of Stephen McIntyre’s faulty work as his own, and as much as 1/3 or more of the Wegman report had been plagiarized. Despite reaffirmation by the NAS, the addition of a dozen other independent reconstructions all showing the same thing, and voluminous evidence from multiple lines of investigation all showing that the hockey stick accurately represents the state-of-the-science, the denialist bloggers still repeat the false talking points coming out of Wegman’s ethically-challenged and factually-deficient report.
There is much more in the book, of course, and along the way Mann also discusses the ubiquitous inability of any denialist argument to stand up to even the most basic scientific scrutiny. He discusses the cadre of industry-sponsored blogs that serve as an echo chamber for denialist talking points, even long after they have been thoroughly debunked many times (including, for example, the falsehood that the hockey stick is broken).
Mann further discusses attempts to intimidate climate scientists in chapters called “Heads of the Hydra” (whenever one false talking point is debunked, two more false talking points are tossed out and/or recycled from the ones already debunked), “The Battle of the Bulge” (about how the denialist industry has made a last ditch effort to harass and intimidate scientists now that the science has become undeniable), and “Climategate: The Real Story” (how the denialist industry coordinated an orchestrated disinformation campaign). Mann’s recounting of how the “hide the decline” false talking point required the convenient omission of 23 words and the combining of two completely unrelated topics for the denialists to create their fake scandal is enlightening.
The final chapter “Fighting Back” is about how climate scientists have started to defend themselves and the science against the vicious harassment and intimidation of the climate denial lobby. One example he lists is Virginia Attorney General Cuccinelli’s witch hunt that was working its way up through the courts. Just this past week the Virginia Supreme Court ruled that Cuccinelli had no basis for pursuing what all parties acknowledge is nothing more than a politically motivated attempt to intimidate scientists who are doing research politicians find ideologically inconvenient.
In an Epilogue, Mann notes that his views of the “role of the scientist” have evolved over the last 10 years. Previously Mann, like most scientists, believed the role of the scientist was to do scientific research and that others should take on the duty of communicating it to the public. Now he believes that it is a responsibility of all scientists to ensure that their science is accurately communicated, and sometimes that means being out there to correct the intentional disinformation pushed by the science denial lobby. All scientists should consider this advice.
I highly recommend this book. I also highly recommend the book Global Warming and Political Intimidation by Raymond S. Bradley, the “B” of MBH98/99. Like Mann, Bradley has experienced first hand the “Serengeti Strategy” of harassment.
Photo Credit and to order the book: Amazon.com
Thursday, March 1, 2012
EPA Releases Chemical Work Plan - Names Chemicals for Risk Assessment
EPA has "developed a work plan that identifies existing chemicals for risk assessment over the next several years." Today they "posted the methodology for developing this work plan, the work plan chemicals identified using the methodology, and seven chemicals for risk assessment development in 2012." EPA also posted an "existing chemicals program strategy," that "includes risk assessment and risk reduction, data collection and screening, and public access to chemical data and information."
We'll examine the strategy and work plans in more detail over the coming days, but here's a quick synopsis. Last September EPA announced that it would seek to identify existing chemicals for risk assessment under TSCA since the TSCA reform legislation was likely not to be seriously discussed in Congress for some time. In a two-step process, EPA identified criteria for prioritizing chemicals based on their hazards, likelihood for exposure, and persistence/bioaccumulation. Scores for each segment are compiled from a variety of sources (to be discussed in future posts), categorized into high, moderate or low ranks, and given an overall score ranging from 1 (low) to 3 (high). Chemicals receiving high scores in all or most of the segments get higher priority for assessment.
Since EPA resources are limited, and likely to get even more limited due to pending budget cuts, they have designated only seven chemicals for the 2012 work plan. Another 76 chemicals have been designated for future year work plans.
More details will come in future posts. The seven chemicals listed for 2012 will be subject to EPA risk assessments. They are:
- Antimony & Antimony Compounds
- 1,2,3,6,7,8-Hexahydro-3,6,6,7,8,8-hexamethylcyclopentag]-2-benzopyran (HHCB)
- Long-chain chlorinated paraffins (C18-20)
- Medium-chain chlorinated paraffins (C14-17)
- Methylene chloride
- N-Methylpyrrolidone
- Trichloroethylene (TCE)
Tuesday, February 28, 2012
ECHA Proposes to List 13 Chemicals as Substances of Very High Concern Under REACH
The European Chemicals Agency (ECHA) has proposed to add 13 additional chemicals to their candidate list of Substances of Very High Concern (SVHC). Each of the chemicals "is classified as carcinogenic, mutagenic or toxic for reproduction." Stakeholders and other interested parties are urged to comment on the proposed listings. Besides toxicity, "information on the uses of the substances is invited."
The public consultation "will be open for 45 days and will end on 12 April 2012." After the consultation period, ECHA will consider all comments and then make final decisions on including the substances on the candidate list. Eventually these substances could be included on the REACH Annex XIV Authorisation List. If that happens then companies will have to apply for authorisation, that is, apply to have their substance remain on the market, usually only for specific controllable uses, limited volumes, and for a limited period of time while substitutes are developed.
More information and the list of chemicals can be found on the ECHA web site.
The public consultation "will be open for 45 days and will end on 12 April 2012." After the consultation period, ECHA will consider all comments and then make final decisions on including the substances on the candidate list. Eventually these substances could be included on the REACH Annex XIV Authorisation List. If that happens then companies will have to apply for authorisation, that is, apply to have their substance remain on the market, usually only for specific controllable uses, limited volumes, and for a limited period of time while substitutes are developed.
More information and the list of chemicals can be found on the ECHA web site.
Sunday, February 26, 2012
Book Review – A Contract with the Earth by Newt Gingrich and Terry L. Maple
This is a rather odd book to review. On the one hand former Speaker Newt Gingrich teams up with the CEO of the Palm Beach Zoo to argue for a “Contract with the Earth” in which all of us, without partisanship, become stewards of the environment. Published in 2007, they note that “as a nation” we must remove our addiction to oil: “By weaning industrial societies from their dependence on fossil fuels, the world would be a far better place.” They implore both parties to take the environment seriously, pleading that “surely our energy problems rise to the level of a presidential crusade.”
Later they quote a coalition of corporate CEOs that together represent an Energy Security Leadership Council:
That was during the Bush administration.
Which gets us to the other hand. While the book argues forcefully for bipartisan (or more accurately, non-partisan) action to deal with climate change, pollution, protection of endangered species, biodiversity, and other environmental values, it is also rife with political innuendo and denialism. Given Gingrich’s recent statements that contradict the profoundly persuasive arguments in this book, it’s unclear whether the self-contradictions are a result of the differing views of the two authors or of the lead author’s political pandering induced by a run for the White House.
Ignoring that aspect for the moment, the book does offer some compelling ideas for how to rid ourselves of our oil addiction and invest in the development of renewable energy. They quote Espy and Winston’s book Green to Gold, in that “smart companies seize competitive advantage through strategic management of environmental challenges.” In other words, smart innovative companies can make a buck and save the planet too! Gingrich and Maple advocate an entrepreneurial approach to dealing with climate change, quoting the Republicans for Environmental Protection:
As I read those final words it struck me – perhaps Newt Gingrich should go back and read his own book.
Photo credit: Amazon.com
Later they quote a coalition of corporate CEOs that together represent an Energy Security Leadership Council:
“America’s oil dependence threatens the prosperity and safety of the nation. Continued policy paralysis is unacceptable precisely because we can take action to improve our energy security. Many challenges lie ahead, but we have no doubt that efforts of the American people will meet with success.”
Which gets us to the other hand. While the book argues forcefully for bipartisan (or more accurately, non-partisan) action to deal with climate change, pollution, protection of endangered species, biodiversity, and other environmental values, it is also rife with political innuendo and denialism. Given Gingrich’s recent statements that contradict the profoundly persuasive arguments in this book, it’s unclear whether the self-contradictions are a result of the differing views of the two authors or of the lead author’s political pandering induced by a run for the White House.
Ignoring that aspect for the moment, the book does offer some compelling ideas for how to rid ourselves of our oil addiction and invest in the development of renewable energy. They quote Espy and Winston’s book Green to Gold, in that “smart companies seize competitive advantage through strategic management of environmental challenges.” In other words, smart innovative companies can make a buck and save the planet too! Gingrich and Maple advocate an entrepreneurial approach to dealing with climate change, quoting the Republicans for Environmental Protection:
“America is ready to meet the challenges posed by global warming. America has the best scientists. America’s businesses lead the world in developing and marketing innovative technologies that transform lives. All that remains is leadership that will channel the unrivaled power and creativity of markets toward developing the solutions we need soon to protect our atmosphere, strengthen American economy, and bring clean prosperity to the world’s developing nations.”
Photo credit: Amazon.com
Monday, February 20, 2012
Global Extinction: Gradual Doom as Bad as Abrupt
According to the National Science Foundation (NSF), "the deadliest mass extinction of all took a long time to kill 90 percent of Earth's marine life--and it killed in stages." What does this mean? According to the authors of a new report, "it shows that mass extinctions need not be sudden events."
In a period called "The Great Dying" that occurred about 250 million years ago, around 90% of all living species disappeared, that is, they went extinct. The authors of a new study published in the Geological Society of America Bulletin show a strong likelihood that this huge mass extinction was at least in part due to massive volcanic eruptions in Siberia. Still, the authors note that this process "phased in over hundreds of thousands of years."
"The world revealed by their research is a devastated landscape, barren of vegetation and scarred by erosion from showers of acid rain, huge "dead zones" in the oceans, and runaway greenhouse warming leading to sizzling temperatures."
So what caused the changes that led to the extinction of most of life on Earth? According to the researchers, volcanic lava flowing "through a large coal deposit...released lots of methane when it burned through the coal. Methane is 30 times more effective as a greenhouse gas than carbon dioxide." And that set the stage for a massive greenhouse effect that overwhelmed the natural balance. According to researcher Thomas Algeo:
"We're not sure how long the greenhouse effect lasted, but it seems to have been tens or hundreds of thousands of years."
For more information, see the NSF press release.
In a period called "The Great Dying" that occurred about 250 million years ago, around 90% of all living species disappeared, that is, they went extinct. The authors of a new study published in the Geological Society of America Bulletin show a strong likelihood that this huge mass extinction was at least in part due to massive volcanic eruptions in Siberia. Still, the authors note that this process "phased in over hundreds of thousands of years."
"The world revealed by their research is a devastated landscape, barren of vegetation and scarred by erosion from showers of acid rain, huge "dead zones" in the oceans, and runaway greenhouse warming leading to sizzling temperatures."
So what caused the changes that led to the extinction of most of life on Earth? According to the researchers, volcanic lava flowing "through a large coal deposit...released lots of methane when it burned through the coal. Methane is 30 times more effective as a greenhouse gas than carbon dioxide." And that set the stage for a massive greenhouse effect that overwhelmed the natural balance. According to researcher Thomas Algeo:
"We're not sure how long the greenhouse effect lasted, but it seems to have been tens or hundreds of thousands of years."
For more information, see the NSF press release.
Wednesday, February 15, 2012
The Scientist: Obama Seeks Science Stimulus
Quick pick from The Scientist: "On Monday (February 13), President Obama released his budget request for the 2013 fiscal year, totaling $3.8 trillion. In the science sector, he requested a 1 percent increase in research spending across the board."
President Obama in his annual budget proposal is attempting to increase funding for the sciences. Unfortunately, the Republican party in the House is attempting to eliminate much of the funding for the sciences.
See all the details in The Scientist.
President Obama in his annual budget proposal is attempting to increase funding for the sciences. Unfortunately, the Republican party in the House is attempting to eliminate much of the funding for the sciences.
See all the details in The Scientist.
Friday, February 10, 2012
EPA Names Lek Kadeli Acting Head of Office of Research and Development (ORD)
In an internal memo, EPA Administrator Lisa Jackson announced that Lek Kadeli will take over as Acting Assistant Administrator of EPA's Office of Research and Development (ORD). Kadeli replaces Paul Anastas, who tendered his resignation last month to return to Yale. Kadeli had been principal deputy assistant administrator for management at ORD and has held several other senior executive positions within EPA and ORD since he came to the Agency in 1990.
Jackson also announced that Ramona Trovato would serve as Kadeli's prinicipal deputy. There had been speculation that Trovato might get the acting AA position. Trovato also has a long history at EPA "as a scientist in a regional lab" and as "a leader on important science and policy issues ranging from radioactive waste management to children's health to groundwater protection."
In her message Jackson noted that:
Jackson also announced that Ramona Trovato would serve as Kadeli's prinicipal deputy. There had been speculation that Trovato might get the acting AA position. Trovato also has a long history at EPA "as a scientist in a regional lab" and as "a leader on important science and policy issues ranging from radioactive waste management to children's health to groundwater protection."
In her message Jackson noted that:
I am confident that both Lek and Ramona will contribute significantly to the EPA’s commitment to setting the standard for environmental science at home and around the world. Indeed, as I have made clear since day one, science will remain at the forefront of all of the EPA’s efforts as we continue to work toward a cleaner, healthier environment for every American.
Monday, February 6, 2012
ECHA Identifies 2300 Chemical Substances for REACH Registration by 2013
A survey of potential registrants by the European Chemicals Agency (ECHA) has resulted in a list of 2,300 chemical substances that are intended to be registered by the 2013 deadline under REACH. Substances that are manufactured or imported into Europe at levels above 100 tonnes per year must be registered by May 31, 2013. This is in addition to the previous deadline of November 30, 2010 for registration of chemicals at volumes greater than 1000 tonnes per year or were substances of very high concern (SVHC).
ECHA will update the list monthly and invites those potential registrants who have not informed ECHA of their intent to do so as soon as possible.
Registrants must prepare an IUCLID dossier containing data requirements as specified in the REACH regulation. The dossier is filed electronically through ECHA's REACH-IT system and must be done prior to the deadline in order to continue to manufacture or import those substances. New substances not on the preregistered phase-in list must submit completed dossiers prior to manufacture or import.
More information can be found in the ECHA press release.
ECHA will update the list monthly and invites those potential registrants who have not informed ECHA of their intent to do so as soon as possible.
Registrants must prepare an IUCLID dossier containing data requirements as specified in the REACH regulation. The dossier is filed electronically through ECHA's REACH-IT system and must be done prior to the deadline in order to continue to manufacture or import those substances. New substances not on the preregistered phase-in list must submit completed dossiers prior to manufacture or import.
More information can be found in the ECHA press release.
Thursday, February 2, 2012
EPA Will Not Change Chemical Data Reporting Deadline Despite House Request
EPA has decided that it will would not change the reporting deadline for the new Chemical Data Reporting (CDR) rule despite a letter from Republican Representative Fred Upton, chair of the House Energy and Commerce Committee. The CDR requires chemical manufacturers to provide data during the period from February 1 to June 30, 2012. The letter from Upton, along with fellow Republican John Shimkus, argued that the reporting rule - which had been delayed by nearly a year already - was overly burdensome to industry. In their January 30, 2012 response, acting EPA toxics chief Jim Jones noted that “the EPA provided a five month reporting period for this first round of reporting to provide additional time for companies to review and understand changes in the reporting requirements, gather the necessary information, and file through the agency's electronic reporting system.”
Jones also noted that, “we believe that the current five month window for companies to report, along with their ability to engage the agency directly on any questions or issues they may have, provides an adequate opportunity for reporting by June 30, 2012.”
The final CDR was published on August 15, 2011, thus giving substantial time for industry to understand their obligations and prepare for the submission. EPA also recently provided guidance for submitting byproduct data, a key concern expressed in the Upton/Shimkus letter. Overall, EPA believes that it has provided substantial lead time and guidance for industry to comply and that the additional delays requested by the Republican members of the House are both unwarranted and would reduce the availability of vital, and Congressionally-mandated, health and safety information from the public.
More information on Chemical Data Reporting can be found on EPA's web site.
Jones also noted that, “we believe that the current five month window for companies to report, along with their ability to engage the agency directly on any questions or issues they may have, provides an adequate opportunity for reporting by June 30, 2012.”
The final CDR was published on August 15, 2011, thus giving substantial time for industry to understand their obligations and prepare for the submission. EPA also recently provided guidance for submitting byproduct data, a key concern expressed in the Upton/Shimkus letter. Overall, EPA believes that it has provided substantial lead time and guidance for industry to comply and that the additional delays requested by the Republican members of the House are both unwarranted and would reduce the availability of vital, and Congressionally-mandated, health and safety information from the public.
More information on Chemical Data Reporting can be found on EPA's web site.
Tuesday, January 31, 2012
Japan Allows 1-week to Register New Chemicals - Don't Miss It
Japan has announced that it will accept applications for manufacture or import of new chemicals meeting their small quantity criteria, but these applications must be filed during a single one-week period from February 28th to March 7th, 2012. This is in accordance with Japan's Chemical Substance Examination and Manufacturing Control law. For readers of Japanese, more information is available on the Environmental agency website.
The announcement was made by the Japanese Ministry of Economy, Trade, and Industry; the Ministry of Health, Labor, and Welfare; and the Ministry of the Environment. The application requirement applies to annual quantities of 1 to 10 metric tonnes and for only chemicals that are new to Japan (existing chemicals in Japan are not included in the requirement).
This annual event has been occurring for the last 8 years, with the number of applications growing from only about 100 in 2004 up to over 1000 by 2010.
Monday, January 30, 2012
ECHA Says "Only Representatives" Can Apply for Chemical Authorization
According to the European Chemicals Agency (ECHA):
"In December 2011, the European Commission services informed ECHA that, in their view, an Only Representative (OR) of a non-EU manufacturer can also apply for authorisation. Following this, ECHA updated the webforms to allow ORs to send their applications while developing long term functionalities in REACH-IT. The relevant Data Submission Manual Part 22 - How to Prepare and Submit an Application for Authorisation using IUCLID 5 is also being updated and will be published once the new version of IUCLID is released, which is currently expected to be during summer 2012."
Previously it was assumed that only a European registrant could apply for authorization under REACH. Authorization is the process by which companies can apply to keep certain uses of their Substances of Very High Concern (SVHC) that have been targeted for banning on the market for a limited period of time while alternatives are developed.
More information on applying for authorization can be found on the ECHA site.
"In December 2011, the European Commission services informed ECHA that, in their view, an Only Representative (OR) of a non-EU manufacturer can also apply for authorisation. Following this, ECHA updated the webforms to allow ORs to send their applications while developing long term functionalities in REACH-IT. The relevant Data Submission Manual Part 22 - How to Prepare and Submit an Application for Authorisation using IUCLID 5 is also being updated and will be published once the new version of IUCLID is released, which is currently expected to be during summer 2012."
Previously it was assumed that only a European registrant could apply for authorization under REACH. Authorization is the process by which companies can apply to keep certain uses of their Substances of Very High Concern (SVHC) that have been targeted for banning on the market for a limited period of time while alternatives are developed.
More information on applying for authorization can be found on the ECHA site.
Thursday, January 26, 2012
With No TSCA Chemical Reform on the Horizon, States Take the Lead
With TSCA reform at the federal level highly unlikely to occur in this election year, the individual states are expected to step up their ongoing battle to protect human health and the environment from chemicals. According to Safer States, "at least 28 state legislatures will consider proposals to address continued concerns about toxic chemicals in consumer products." This builds on "over 80 chemical safety laws [that] have been passed with an overwhelming margin of bi-partisan support in statehouses across the country" during the last nine years.
Safer States is "a network of diverse environmental health coalitions and organizations in states around the country" and is a part of Safer Chemicals, Healthy Families, a "coalition of groups united by their common concern about chemicals in our homes, places of work, and products we use every day."
The organization has posted what they see as highlights of the 2012 state legislative efforts, as follows:
The full Safer States press release can be viewed and downloaded as a PDF here.
Safer States is "a network of diverse environmental health coalitions and organizations in states around the country" and is a part of Safer Chemicals, Healthy Families, a "coalition of groups united by their common concern about chemicals in our homes, places of work, and products we use every day."
The organization has posted what they see as highlights of the 2012 state legislative efforts, as follows:
- Identification and Disclosure of Chemicals Harmful to Children. At least 13 states, including Alaska, Connecticut, Florida, Illinois, Maryland, Massachusetts, Michigan, Minnesota, New York, New Jersey, Oregon, Vermont, and Washington will consider policies to identify and ultimately reduce exposures to chemicals of concern, including prioritizing chemicals for state action and requiring manufacturers of consumer products to disclose the chemicals in their products.
- BPA Phase Outs. At least 20 states will consider policy to restrict the use of the hormone-disrupting chemical BPA in infant formula cans, other food packaging, children's products, and receipt paper. Alaska, Alabama, Arizona, Connecticut, Colorado, Georgia, Hawaii, Illinois, Iowa, Kentucky, Massachusetts, Maine, New Hampshire, New York, North Carolina, New Jersey, Tennessee, Virginia, West Virginia and Wisconsin are all states considering such legislation.
- Tris Flame Retardant Phase Outs. At least four state legislatures will introduce policies to phase out the use of the flame retardant chlorinated Tris in children's products. Chlorinated Tris is a flame retardant that was removed from children's pajamas in the 1970s because of concerns over adverse health effects, including cancer, but has reappeared in other children's products. Connecticut, Maryland, New York, and Washington are legislatures considering such a ban. In addition, Alaska, Michigan, New Jersey and New York legislatures will consider policies to reduce exposure to the flame retardant decaBDE.
- Green Cleaning in Schools. Earlier this month, Vermont passed policy requiring manufacturers to only sell environmentally preferable cleaning products to schools. Massachusetts, New Jersey, New York, and North Carolina are considering similar policy.
- Cadmium Bans in Children's Products. At least 5 states will be introducing or have introduced policies to ban the use of cadmium in children's products, including Hawaii, Maryland, Michigan, New York, and Tennessee. Cadmium is linked to cancer and other health effects.
- Other policies. Oregon has introduced policy to require the state to reduce toxics through its procurement process. New York is considering policy to restrict formaldehyde in beauty products. Massachusetts and Georgia are also considering policy to improve the safety of cosmetics. Other states have introduced individual chemical restrictions, such as lindane in Michigan and perchloroethelyene in Vermont.
The full Safer States press release can be viewed and downloaded as a PDF here.
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