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“SOCMA understands that TSCA modernization is a complex issue that deserves close scrutiny,” wrote Lawrence D. Sloan, president of SOCMA. “Many relevant factors should be considered, most of which, we believe, fall outside the statute itself.”
Sloan added that TSCA critics selectively cite chemical statistics that paint an incomplete picture of TSCA’s effectiveness. He underscored the fact that these statistics alone make it appear as if the TSCA has failed due to a relatively low number of restricted chemicals when, in fact, there is a great deal of testing conducted. He added that most chemicals can be used safely and therefore do not require additional restrictions. He continued by noting that there are many other federal laws that govern chemicals management and that advances in the field of analytical chemistry should be acknowledged before placing blame solely on the TSCA for increased exposures.
SOCMA asked that the subcommittee consider a variety of metrics to evaluate the TSCA prior to introducing new legislation, such as the number of new chemicals reviewed by the Environmental Protection Agency (EPA) under Section 5 since the TSCA’s inception; the number of Pre-Manufacturing Notices (PMN) withdrawn as a result of those reviews; the number of PMNs whose review periods were voluntarily suspended while the submitter conducted tests or gathered other data; the number of Significant New Use Rules (SNURs) issued by the EPA; and the number of existing chemicals actually in commerce.
“Ultimately, success will not depend solely or primarily on how many chemicals are restricted, but on the net health, environmental and economic effects of implementing these laws,” Sloan said.
For additional details, visit www.socma.com.