Australia IMAP Lists 3000 "Stage One" Chemicals for Assessment

The Australian chemicals agency, which goes by NICNAS, has announced that it will implement its new Inventory Multi-tiered Assessment and Prioritisation (IMAP) framework "in a staged manner." Beginning July 2012, "NICNAS will begin assessing around 3,000 existing chemicals," which are now designated “Stage One chemicals.”

The characteristics used to identify "stage one" chemicals are listed in the table on the NICNAS site and include a) chemicals for which NICNAS holds exposure data, b) chemicals identified as
a concern or for which action has been taken overseas, and c) chemicals detected in international studies analysing chemicals present in the blood in babies’ umbilical cords.

NICNAS has set up an online searchable database for anyone wishing to find out which chemicals are included in Stage One.

Factsheets on the program can be found here.

EPA Will Identify Priority Chemicals by Thanksgiving (or so)

EPA will identify chemicals to be prioritized sometime this fall as it tries to move forward under the old TSCA as Congress makes no progress on developing a new TSCA.  To do so EPA will take into consideration feedback they received from a variety of stakeholders in two recent outreach attempts related to their proposed prioritization process. 

EPA introduced its proposed prioritization scheme and "discussion guide" back in August.  They then had a webinar on September 7th to give an overview of the proposed scheme and to invite feedback.  Finally, EPA also invited the public to share their thoughts in an online discussion forum.  That discussion forum closed on September 14th.


All comments received from stakeholders are now being assimilated and reviewed by EPA staff, who are working to identify chemicals to be prioritized for review.  In general the feedback was very constructive and included both concerns for the data sources being proposed as well as suggestions for other data sources to include in the evaluation. Other stakeholders cautioned that the use of production volume as a surrogate for exposure could lead to chemicals with very low risk being prioritized while chemicals of low production volume by high exposure potential, and thus risk, might be left out.  Some stakeholders suggested the addition of additional health effects such as endocrine disruption, neurotoxicity and skin or respiratory sensitization be used early in the prioritization process, while others cautioned that the process could get bogged down in the minutia if too many factors were included in the first step.

More information on the EPA chemical prioritization can be found on the discussion forum web site and EPA's existing chemicals "Identifying priority chemicals for review" page.

ACC's Chemical Prioritization Tool - EDFs Analysis is One Thumb Up, One Thumb Down

Last week I reported on an analysis of the EPA's proposed chemical prioritization tool done by Richard Denison of the Environmental Defense Fund (EDF).  Today I report on Denison's follow up analysis on the counter-proposal prioritization scheme released by the American Chemistry Council the day prior to EPA's webinar.  I'll start with Denison's conclusion:

"While ACC’s tool has some serious flaws and is not something that EPA has the authority or resources to utilize under current TSCA, ACC has put forth a serious proposal for prioritization that should help to raise the level of debate over this critical issue in TSCA reform."

As suggested, Denison notes that the ACC proposal offers some "refreshing elements and acknowledgements."  He describes it as "substantive and specific" and is "welcome in several ways."  He goes on to summarize some of the areas he feels are constructive (see his full blog entry).  Notwithstanding these kudos, however, Denison does suggest that ACC's proposal seems better suited for a full TSCA Reform element and that implementation of the ACC plan is not likely to be possible under the current (and likely future) resource and funding constraints limiting EPA's activities.


Denison finds that there are "a number of quite problematic aspects of ACC's proposal," including:

• Overly rigid rules applied in lockstep: Denison finds ACC's proposed "equal basis" rule to be "sleight of hand" that will "rule out any types of information that may indicate a hazard or exposure of high concern unless it has been measured across basically all chemicals subject to prioritization."  The "high hazard and high exposure" rule would allow prioritization of only those chemicals "for which high hazard and high exposure can be demonstrated;" a proposal that Denison finds to be "simply shortsighted." He also critiques ACC's "persistent and bioaccumulative" rule, which he finds includes "extremely narrow definitions of P and B" that would avoid prioritizing chemicals that would in fact be either P or B (or both).
• Consistent use of the least conservative classification values: Denison points out that the ACC proposal relies on the classification criteria developed under GHS, which he generally supports.  However, he does quibble with what he feels are two limitations - GHS doesn't include every endpoint of concern and ACC chooses the least conservative values instead of adhering to GHS' cutoff values faithfully.  A choice where Denison feels "ACC fails badly."
• Over-relying on limited exposure information and discounting evidence of hazard: Denison notes that ACC's tool lumps together its health and environmental hazard rankings into a single score while combining scores for its three exposure elements, which "means that a chemical that harms both people and other organisms only gets counted once, while a chemical that is low-volume and used only as an intermediate and is not P or B gets credit for being of low concern for all three attributes."  The way the tool handles hazard vs exposure rankings also is likely to skew the results such as to avoid prioritization for chemicals that could indeed be problematic.

Despite these significant critiques, Denison feels that the ACC prioritization tool is a good effort and a basis for informed debate as the process moves forward.  Combined with his previous critique of the EPA prioritization proposal, there clearly is a path forward for enhancing chemical regulation and improving protection of the environment and human health.  But will it happen?

Avoiding Paralysis by Analysis - EDF's Analysis of the EPA TSCA Chemical Prioritization Proposal

Last week the USEPA held a webinar to introduce their proposal for how they will attempt to prioritize TSCA chemicals for closer assessment.  One day prior to the webinar the ACC announced its own competing prioritization scheme. Earlier this week, Environmental Defense Fund Senior Scientist Richard Denison offered his views on the EPA scheme, which he called "a sensible approach to identifying chemicals of concern." [Note: Denison will be addressing the ACC proposal in a following post on the EDF web site.]

The "paralysis by analysis" noted to in the title refers to the futility of asking EPA to evaluate the entire TSCA Inventory akin to the Canadian approach.  The Canadian approach was actually "mandated by statute" (via the 1999 amendments to the CEPA) and both Environment Canada and Health Canada were given "seven years and a major infusion of new resources" just to complete the first phase of the process.  According to Denison, with nearly four times as many chemicals on the Inventory, and "without the authority and the resources, well, that's just a recipe for paralysis by analysis" to ask EPA to do the same. 

Which is why the EPA proposal is so reasonable, according to Denison.  He indicates that EDF and the Safer Chemicals Healthy Families coalition "generally support EPA's approach and believe it strikes the right balance between clarity and transparency and avoiding paralysis by analysis."  Denison does, however, offer a series of 10 additional suggestions for improving the EPA proposal.  The full list can be seen on the EDF blog page, but include broadening the sources of data specified in Step 1 (perhaps by including some of the source from Step 2), consideration of the published literature, adding specific criteria for children's health and exposure, expanding the range of "vulnerable subpopulations" beyond just children's health, and providing additional clarity on how EPA plans to move from Step 1 to Step 2.

Overall, Denison finds that the attempts by EPA to reintroduce "action" into their proposed prioritization and action plan process are much needed.  He welcomes EPA looking at chemicals in commerce to identify those for which it would be prudent to take a closer look at their potential risk.  And with the additional actions suggested, he believes that it is a good step in the right direction.

To read EDF's analysis and the full list of suggestions, see Richard Denison's blog entry for September 13, 2011.

ACC Proposes TSCA Prioritization Tool to Improve Chemical Review Process

The American Chemistry Council (ACC), a trade association representing many large chemical manufacturers, has proposed a new prioritization tool "to increase effectiveness of EPA's chemical review process."  The press release comes in a preemptive strike a day before EPA holds a webinar in which it will describe its own proposal for prioritizing chemicals.

ACC states that "EPA does not have a systematic way to determine which chemical uses need further characterization" and worries that "EPA may be wasting time, energy and resources gathering additional information on already well-understood chemicals."  According to their fact sheet and an accompanying powerpoint presentation, ACC's prioritization tool "would be administered by EPA" to:

• Evaluate chemicals against transparent, consistent, scientifically-based criteria focused on the hazard associated with the chemical, how the chemical is used and how people or the environment are exposed to the chemical;
• Ascribe a score based on the criteria;
• Rank order chemicals based on their scores and the professional judgment of EPA officials; 
• Utilize the rankings to determine which chemicals should be given full risk assessments

Individual criteria for ranking chemicals would include human health hazards (e.g., carcinogenicity or reproductive/developmental toxicity), potential environmental effects, the industrial, commercial and consumer uses, persistence and bioaccumulation potential, production volume, and other factors such as use in children's products or detected in biomonitoring programs.

EPA's prioritization scheme to be discussed tomorrow (September 7, 2011) differs significantly from the ACC plan.  ACC has clear scoring criteria for all chemicals where the EPA plan relies more on prior listings of chemicals by other regulatory bodies.  ACC's plan also gives greater weight to potential exposure (i.e., focus on risk) whereas EPA's plan would rely more on hazard for at least its first steps.

More information on the ACC prioritization proposal can be found on their TSCA prioritization page, including links to criteria documents, presentation and background information.

EPA to Discuss TSCA Chemical Prioritization Process in Upcoming Webinar - Invites Comments

The USEPA is reevaluating and seeks to enhance their current chemicals management program as authorized under the Toxic Substances Control Act (TSCA).  As part of this reevaluation EPA has scheduled a webinar on the prioritization factors and data sources the Agency plans to use to identify priority substances.  EPA is also inviting the public to share their thoughts in an online discussion forum.


The discussion forum seeks comments on two steps in the process.  The first step is prioritization and is split into two substeps - the priority factors to be used to identify substances of high priority, and the sources of data for those factors.  The second step is to look at additional factors and sources for further analysis beyond the prioritization step.

More information and links to the discussion forum for each of the steps can be found on the
EPA discussion forum site.  All comments will be reviewed by the EPA, though since this is not a formal rule-making EPA will not respond directly to each comment.  The online forum is now open and will remain open through 5:00 pm EDT on September 14, 2011.

In conjunction, EPA is inviting participation in a webinar that will discuss the prioritization factors and data sources.  The webinar will be held on Wednesday, September 7, 2011 from 1:30 to 4:30 pm EDT.  Interested parties may register for the webinar here.

Prior to the webinar or submitting comments in the online discussion forum, all are encouraged to read EPA's background paper and discussion guide, which lays out the current thought process.  This can be downloaded as a PDF file here.