Regulatory initiatives related to the "new Toxic Substances Control Act (TSCA)" are rapidly advancing, creating challenges for companies that want to provide input to the US Environmental Protection Agency (US EPA) on the implementation of the new TSCA requirements and understand the implications of the risk assessments coming down the pike.
The most imminent deadline (March 15) involves risk assessment scoping for the first 10 "high priority" existing chemicals. At this time, US EPA is requesting that chemical manufacturers, importers and users provide US EPA with any information on these chemicals' uses and exposures, including information on recycling and disposal, in order to ensure that the risk evaluation scope is accurate and comprehensive. Interestingly, once the scoping document is released, there will be no opportunity for public comment, making this upcoming deadline the only "official" opportunity to make sure US EPA's evaluation is inclusive in its consideration of any foreseeable uses of these 10 existing chemicals. The consequences of US EPA failing to consider specific uses of these chemicals are unclear, but one possibility is that unevaluated uses could be restricted in the future.
If your company manufactures or uses products that contain the first 10 high priority chemicals being evaluated by US EPA under the new TSCA, you may want to inform US EPA about the chemicals' current uses if they are not already captured in the documents released earlier this month regarding "Preliminary Information on Manufacturing, Processing, Distribution, Use, and Disposal" for each chemical. US EPA is expected to issue guidance soon that will outline a process for interested parties to submit draft risk evaluations of the first 10 high priority chemicals for US EPA to consider. Companies currently relying on any of these chemicals for their business should consider submitting information to inform US EPA's risk assessment or may wish to consider alternative product formulations that do not include these chemicals.
Gradient is actively participating in all aspects of the new TSCA implementation and is following developments closely. If you need assistance in proactively preparing for both new and existing chemical evaluations and/or need help understanding the implications of upcoming regulatory milestones, please do not hesitate to contact us.
Gradient is an environmental and risk sciences consulting firm renowned for our specialties in Toxicology, Epidemiology, Risk Assessment, Product Safety, Contaminant Fate and Transport, Industrial Hygiene, Geographic Information Systems, and Environmental/Forensic Chemistry. We employ sound science to assist national and global clients in resolving their complex problems relating to chemicals in the environment, in the workplace, and in consumer products.