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Call for TSCA modernisation

Hydrocarbon Engineering,

Charles T. Drevna, AFPM President issued the following statement on the House Energy and Commerce Subcommittee on Environment and the Energy hearing titled ‘Testing of Chemicals and Reporting and Retention of Information under the Toxic Substances Control Act Sections 4 and 8.’

‘The TSCA is a unique statue in that it has as much to do with commerce and the manufacturing supply chain as it does human health and the environment. TSCA gives the Environmental Protection Agency (EPA) broad power to regulate chemicals in commerce. While AFPM supports rational modernisation of TSCA, great care must be taken so that manufacturing supply chains are not disrupted. AFPM supports a federal preemption to ensure that the interstate flow of raw materials and goods is unimpeded by a patchwork of state laws, which would have a crippling impact on the manufacturing sector.

‘The current TSCA statute provides a solid backbone for chemical regulations however, AFPM sees room for improvement. Congress should direct EPA to prioritise chemicals in commerce. We view the prioritisation efforts under the Canadian Chemical Management Program as a reasonable, achievable model. Prioritisation along these lines takes a screening level look at chemical hazard and exposure that tells scientists whether or not more work is needed to deem a substance as safe for its intended conditions of use. Currently, EPA has sophisticated and protective models it uses to evaluate the potential hazard of chemicals. The Agency collects data under the Chemical Data Reporting rule to determine the exposure potential of chemical substances, so there are no technical or practical reasons that EPA cannot prioritise chemicals for further work.

‘Congress should also include provisions that increase scientific quality and transparency at the Agency. Specific language should require EPA to develop criteria by which the Agency and public can judge the quality of scientific studies under consideration, as well as EPA risk assessments.

‘AFPM believes that TSCA should be a tiered, targeted and risk based approach, which especially holds true for testing and data collection. A tiered approach begins with the use of existing information, protective models and structure activity relationships. If there is an unreasonable amount of scientific uncertainty at a screening level, then the substance would be subject to the next tier in which information is collected to reduce the uncertainty. All decisions for tiered and targeted testing, and information collection should be based on risk, which means that both hazard and exposure are considered throughout the collection and assessment processes.

‘AFPM urges Congress to move forward with a bipartisan approach to TSCA reform, which will help to ensure that chemicals are used safely and as intended, and allows US petrochemical manufacturers to remain competitive in the global market.’

Adapted from a press release by Claira Lloyd.

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