ACC-tung Baby: New Tool For TSCA

Pressure to modernize TSCA is mounting from all sides, and the American Chemistry Council (ACC) is offering a tool that agencies can use to do something about it.  The ACC is proposing a chemical prioritization system that it believes could be used by the Environmental Protection Agency (EPA) to determine which chemicals warrant additional review and assessment.

Achtung means “Pay attention” in German, and the world is indeed paying attention to TSCA reform.

ACC President and CEO Cal Dooley said as part of the new tool’s announcement, “As outlined in ACC’s principles for modernizing the Toxic Substances Control Act (TSCA), establishing a clear and scientifically-sound prioritization process is key to creating a world-class chemical management system.”

The 35-year-old TSCA law does not dictate a process to utilize the information currently available to prioritize chemicals for review.  ACC’s approach offers one way to evaluate chemicals against transparent, consistent and scientific criteria that take into account both hazard and exposure. In this system, chemicals are given a score based on certain criteria and then ranked based on both:

  1. scores, and
  2. the agency’s best professional scientific judgment

Those rankings would then be used to determine which chemicals should be referred to EPA’s Office of Chemical Safety & Pollution Prevention for further assessment.

Conflict of interest? The obvious problem with ACC contributing a chemical prioritization tool to EPA lies in seemingly inevitable conflicts of interest where an industry-backed association has a stake in evaluating its own products (in this case chemicals) for the marketplace.

ACC says its prioritization tool is not intended to produce conclusions about which chemicals necessarily present a risk to human health or environment. The tool is, apparently, just a gift, simple as that.

EPA’s stakeholder meeting on prioritization. On Sept. 7, before the announcement, representatives from ACC met with officials at EPA to discuss the tool in conjunction with the agency’s stakeholder dialogue on prioritization.

[EPA is opening an online discussion forum for comment from hrough Sept. 14 to get input on the prioritization factors and data sources the Agency plans to use to identify priority chemicals for review and possible risk management action under TSCA.  Participate here.]

“We are glad that EPA has recognized the urgent need to prioritize chemicals for review,” said Dooley. “ACC welcomes the opportunity to participate in [this] dialogue and hopes EPA will utilize our concepts to develop a consistent and transparent prioritization process.”

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About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.