The Environmental Protection Agency (EPA) held a public meeting on February 14 to collect information on 10 chemicals in commerce. SOCMA members are seeking clarification from EPA regarding the type of information EPA wants, specifically as it relates to intended uses of the chemicals. This is a major milestone in the implementation of the new Toxic Substances Control Act (TSCA) and potentially a sign of things to come.
The chemicals, which were based on their hazard and the public’s potential exposure
, were the first 10 selected from the list of 90 chemicals on the 2014 update to the TSCA Work Plan. The chemicals are:
- Carbon Tetrachloride
- Cyclic aliphatic bromide cluster
- Methylene chloride
- Pigment Violet 29
EPA reached out to numerous companies and trade associations over the past couple of months seeking information regarding the “conditions of use” involving these chemicals to help them establish a scope for the risk evaluations. During the meeting, EPA reiterated its interest in any information that would help the agency at this stage of the process. View the EPA presentations on the scoping exercise here
The agency is interpreting conditions of use broadly, requesting large swaths of information that may or may not be related to where the greatest potential risks (hazard x exposure = risk) may occur. Such an approach raises concerns about unnecessary burdens being imposed on the agency and industry alike and the relevancy of such data. Furthermore, large data dumps have folks questioning what concerns, in fact, the EPA is honing in on, and its ability to meet statutory deadlines. The possibility for “analysis paralysis” is a real concern, since all stakeholders should have an interest in expeditious decision-making based on sound science.
It is typically beneficial to provide EPA as much information as possible. In the absence of actual data, EPA will use its very conservative estimates. And, it seems the estimates have become more precautionary than ever. SOCMA believes it would behoove the agency to be more specific about the information it wants and focus limited resources on where the concerns are greatest.
You can access the EPA presentations here
, as well as contacts for each of the first 10 substances:
EPA will accept written comments and materials submitted to the dockets on or before March 15. Additional information docket numbers and a list of EPA contacts managing each of the chemicals again can be found here
Do not hesitate to contact Dan Newton
at (571) 348-5122 to help facilitate discussions with the agency and share comments and feedback.