I Wish I Were Far From the Madding Crowd

March 8, 2010

Identifying dangerous chemicals

In 1997, the Environmental Defense Fund published Toxic Ignorance, a report on the lack of basic toxicity information about many industrial chemicals.

Thirteen years later EDF is still pursuing improving chemical testing and assessment data for High Production Volume chemicals.

The law governing the production of toxic chemicals is called the Toxic Substances Control Act (TSCA).  EDF’s Richard Denison, among others, has been calling for reforming U.S. chemicals policy through strengthening TSCA (his blog on chemicals and nanotechnology is in my blogroll).  In one post he describes some of the actions taken under Lisa Jackson, Obama’s EPA Administrator.

Of note is the fact that EPA announced late last year that it was moving from a voluntary program called ChAMP to an enhanced chemical management program.  (EDF blog posts on problems with ChAMP, a now superseded program)

In addition to its Toxic Ignorance, EDF has published more reports recently

  • EDF’s 2007 report Not That Innocent documented the urgent need for policy reform. Our analysis contrasted U.S. policies with those in Canada and the European Union and identified “best practices” culled from all three systems that together create a vision for future U.S. chemicals policy.
  • Our September 2008 report Across the Pond assessed one of the first impacts that the new European regulation called REACH will have on U.S. companies and chemicals: REACH’s identification of “substances of very high concern.”
  • EDF scientist Richard Denison’s paper Ten Essential Elements in TSCA Reform, published in January 2009 in the Environmental Law Reporter, laid out a blueprint for new legislation to replace the outmoded Toxic Substances Control Act of 1976.

(from the EDF page on “Chemicals Policy Reform”)

EDF is also a founding member of the Safer Chemicals, Healthy Families campaign, which issued its own Platform for Reform of TSCA.

Why is this important? Well, because there’s an awful lot we don’t know about chemicals and their effect on health.  Denison addresses this in a blog post back in May 2009.  Among the things he advocates there (emphasis in original):

  • For each chemical assessed, clearly identify and communicate to the public all gaps or quality concerns in available data.  (My comment: It is interesting to contrast EPA’s approach vs. that of ATSDR in its Toxicological Profiles.  (alternate URL: http://www.atsdr.cdc.gov/toxpro2.html) See below for more info on ATSDR.)
  • Stop assigning low-priority rankings to chemicals, especially those with data gaps in the most basic, minimum set of screening-level hazard data. As we said before, it’s one thing for EPA to identify as high-hazard those chemicals where, despite the data gaps, available data demonstrate high toxicity. It’s quite another for EPA to effectively exonerate chemicals as low-hazard or low-priority when not even a bare-minimum data set is available for them.
  • Adopt a health-protective approach to hazard screening: Where data are uncertain, of questionable quality or equivocal, assume a hazard exists until and unless a chemical’s manufacturer provides the data to show otherwise.


The Agency for Toxic Substances and Disease Registry (ATSDR), based in Atlanta, Georgia, is a federal public health agency of the U.S. Department of Health and Human Services.  ATSDR’s mission is to determine human health effects associated with toxic exposures, prevent continued exposures, and mitigate associated human health risks at Superfund sites.

ATSDR first identifies data needs in its Toxicological Profiles for certain substances. The data needs are then subjected to further evaluation and prioritized.  When data gaps are identified, they are described in the documents.  (If you look at any of the Tox Profiles, you will see a subsection in several chapters called “Adequacy of the database.”)

While the Tox Profiles cover very nasty chemicals, the irony of this is that these are chemicals found at Superfund sites (of which, according to ATSDR, there are about 1,200).  However, many of these same chemicals are still being manufactured (as well as chemicals for which we have even less data than the Tox Profile ones!) in plants all over the country and the number of places probably far exceeds 1,200.

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