M8.4- Chemical Policy Reform

I chose to read about Reform no.5 of the Louisville Charter, which calls for requiring comprehensive safety data for all chemicals. We know chemicals are hardly regulated, but this piece of the Louisville Charter was eye-opening.

• Reform no.5 addresses the lack of publicly available information about the effects of many chemicals on human health and environment.
• It calls for manufacturers of chemicals to be required to provide health and safety information as a condition for placing and keeping a chemical on the market. For most chemicals on the market, little or no evidence is publicly available about whether they are hazardous, whether they’re present, or if/the degree to which humans/environment are exposed.
• The charter holds that the chemical industry must provide enough reliable information to the public to permit a reasonable evaluation of the safety of chemicals to human health and the environment.
• This should be required as a condition for placing or keeping a chemical on the market. Tens of thousands of chemicals have entered the market with little to no government review or regulation. One EPA study showed that a full set of even limited “Screening Information Data Set (SIDS)” information was publicly available for only 7% of the “High Production Volume (HPV)” chemicals and that no basic toxicity of information for either health or environmental effects was publicly available for 43. 
• The root of the problem is that our existing environmental laws reflect an outdates, incorrect view of chemicals, a belief that only some of the many important chemicals in commerce are likely to be hazardous.
• Research over the last few decades has shown that many chemicals have a wide variety of adverse effects that may be acute, but often may emerge only many years after low levels of exposure (carcinogens, mutagens, reproductive toxins, neurotoxins, immunotoxins).
• Reform no. 5 calls for a “No Data No Market” policy, which I absolutely love.
•  The existing market is incapable of providing incentives for production and dissemination of that needed information.
•  The governments goal should be to create the conditions that are necessary for the proper operations of our existing institutions for controlling chemicals.
•  Benefits severely outweigh costs of implementing regulation program.

• The Toxic Substances Control Act of 1976

o   The only federal law that broadly provides for regulation of most chemicals both before and after they enter commerce.

o   Several sections of TSCA give EPA authority to require industry to generate and provide safety info about their marketed chemicals, but their authority is tightly circumscribed.

o   All chemicals that were in commerce as of 1979 were “grandfathered” into TSCA, meaning they do not require a systematic review of their effects on human health and the environment. These still constitute vast majority by weight of the chemicals on the market today, and TSCA is clear that EPA must consider environmental, economic, and social impacts when evaluating whether a risk is unreasonable.