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Volume 87 Issue 42 | p. 4 | Letters
Issue Date: October 19, 2009

Endocrine Disrupters Drive TSCA Reform

Department: Letters

A 30% increase in the number of chemicals registered under the Toxic Substances Control Act since 1979 is irrelevant to the chemicals bisphenol A, phthalates, and brominated flame retardants because they were commercialized long before TSCA was enacted (C&EN, July 27, page 37). EPA's new premanufacturing notification (PMN) program has been effective insofar as it encourages prescreening by companies during R&D before PMNs are submitted.

Endocrine disruption is the current panic of the day and has yet to be addressed by a verifiable standard test methodology. EPA is working toward a valid testing program and can easily work it into the PMN program once there is consensus on a scientific approach.

Where TSCA has been abysmally implemented is in the identification and control of significant risks presented by existing chemicals because of EPA's failure to take measured, prioritized steps to identify and manage the most serious risks. Instead, EPA continued to make unmanageable attempts to obtain and sift through massive amounts of data on as many chemicals as possible and to consider a total ban as the only control option. The Obama Administration sees the European Union's Registration, Evaluation, Authorization & Restriction of Chemical substances program (REACH) as the model for TSCA "reform." Talk about over-REACHing. I think we will see implosion in Europe as EU governments and companies collapse from the pressure to collect, collate, and act on millions of data elements.

Although some streamlining of TSCA may be needed to ease EPA hurdles to managing existing chemicals, there is tremendous strength in the current language of the act to ensure reasoned decisions are made before seriously restricting commercial activity. It is ludicrous to think that some magical test will determine "safety." We need flexible standards of review and support for continuous improvement, not authorization for default bans at the tweet of every preliminary finding seen in a quick-and-dirty study. ACS needs to support good scientific inquiry and utilization of facts and solid theory in the regulation of the chemical enterprise.

Green chemistry-which uses those magical "inherently safe" chemicals-will not be able to be developed and commercialized to substitute for all current commercial chemicals for a long time, if ever. In the meantime, let's focus on the full array of ways to properly manage chemical risks throughout their lifetime.

Georjean Adams
St. Paul, Minn.

 
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