Pressure Points
The Importance
of use & exposure:
Acting as a trusted partner
Consumers and workers should be able to feel confident
that regulations are developed based on the
best available science. We all benefit when risk evaluation
relies on data and information, not perception or fear.
Under the 2016 amendments to the Toxic Substances
Control Act (TSCA), The U.S. Environmental Protection
Agency (EPA) is mandated to evaluate existing chemicals
using risk-based assessments in a transparent manner with
clear deadlines. These assessments determine whether a
chemical substance presents an unreasonable risk to human
health or the environment under the “conditions of use,”
including an unreasonable risk to a relevant potentially
exposed or susceptible subpopulation. If the EPA finds that
a chemical poses an unreasonable risk at any stage of that
chemical’s lifecycle, EPA is required by TSCA to reduce
those risks through regulation, which could restrict or end
the use of a chemical.
The EPA has selected the following 10 chemicals to
undergo the first set of risk evaluations: Asbestos, 1-Bromopropane,
Carbon Tetrachloride, 1,4-Dioxane, Cyclic
Aliphatic Bromide Cluster (HBCD), Methylene Chloride,
N-Methylpyrrolidone, Perchloroethylene, Pigment Violet
29 and Trichloroethylene. To ensure that any regulations
developed based upon these risk evaluations come from the
best available science, our industry must work collaboratively
with the EPA during its process to make sure that it has the
most up-to-date and complete information for use in their
assessments.
This is especially true for product manufacturers, who have
deep expertise in the “conditions of use” for their products.
Conditions of use
“Conditions of use” is an important term because these are
the circumstances in which a chemical substance is intended,
known or reasonably foreseen to be manufactured,
processed, distributed in commerce, used or disposed of.
The term “exposure” is the contact made between a chemical,
physical or biological agent and the outer boundary of
an organism.
The industry knows the products they manufacture, the
ingredients they utilize and how those products should be
used better than anyone else. It is critical that companies
up and down the supply chain—both suppliers and manufacturers—
share the data that the EPA will need to properly
perform its risk evaluation on the conditions of use of interest
(e.g., hazard, exposure, potentially exposed or susceptible
subpopulations), in addition to other information.
We have the opportunity to engage with the EPA early
and throughout its process to share expertise, data and act as
a trusted partner so that it can focus their resources where it
should and have an improved understanding of the chemicals
under review.
If suppliers and manufacturers do not collaboratively
share data, the EPA could be making decisions based on
incomplete information. You and your company do not have
to undertake these risk evaluations on your own. Industry
can and should work together within trade associations and
with pertinent consortia to gather or develop the data that is
required for this process. A collaborative and organized data
development and collection process will ultimately benefit
the entire industry, especially as the EPA grows the list of
chemicals it is evaluating.
How we engage as an industry during this first round of
evaluations will set the tone for those to come. Our industry’s
reputation as a trusted and collaborative partner of the
EPA is of the utmost importance and will no doubt play
an important role as future regulations are discussed and
promulgated.
HCPA has been actively involved in the EPA’s risk evaluations
by participating in stakeholder meetings, reviewing
materials and submitting comments, meeting face-to-face
with the EPA and giving presentations to ensure the agency
is fully aware of association members’ products and interests.
HCPA will continue to represent our members as the evaluations
progress, and I encourage all of you to join us as we
work with EPA to ensure a business environment that fosters
growth and innovation. Spray
10 Spray August 2018
“Conditions of use” is an important
term because these are the
circumstances in which a chemical
substance is intended, known or
reasonably foreseen to be
manufactured, processed,
distributed in commerce, used or
disposed of…
NICHOLAS GEORGES
Director, Scientific Affairs, HCPA