If you have an ACS member number, please enter it here so we can link this account to your membership. (optional)

ACS values your privacy. By submitting your information, you are gaining access to C&EN and subscribing to our weekly newsletter. We use the information you provide to make your reading experience better, and we will never sell your data to third party members.



Proper ConsiderationOf TSCA

November 11, 2013 | A version of this story appeared in Volume 91, Issue 45

Reform of the Toxic Substances Control Act is needed, but a guest editorial and the letter “Clarifying TSCA” by Howard S. Bender include misconceptions (C&EN, Aug. 12, page 3, and Sept. 9, page 9). Since TSCA was enacted, it has evolved and includes probably more than 60,000 compounds. Because many of the compounds listed have since been taken off the market, considerably less than the total number are currently being used and marketed.

Many of the compounds are of natural origin in addition to being produced synthetically. It is not true that there is no toxicity information for any of the compounds. For thousands of TSCA compounds, peer-reviewed toxicity data and information are available from numerous databases and reports. For example, “Sax’s Dangerous Properties of Industrial Materials” has information on some 28,000 TSCA compounds, and the Merck Index has data on some 18,000 of the compounds.

There should be some realistic time limit imposed on testing for TSCA-listed chemicals, especially those compounds for which no data exist. International cooperation can be achieved, for example, through Europe’s REACH (Registration, Evaluation, Authorisation & Restriction of Chemicals) program. Commercial mixtures should be tested but only after appropriate data are obtained for the components. Some materials, however, are produced only as mixtures. All testing methods including the cited high-throughput in vitro screening should be rigorously evaluated, and the latter should probably be used only as a “first pass” test. Priority in regulation should be based on environmental toxicity factors.

Proper consideration of what TSCA is and is not is essential to providing a win-win conclusion for all.

Robert E. Buntrock
Orono, Maine



This article has been sent to the following recipient:

Chemistry matters. Join us to get the news you need.