WASHINGTON, DC — In what may be a sign of broader chemical reform coming out of Washington soon, the EPA this month announced that it would begin testing some of the most widely used chemicals for toxic and environmental effects.
A rule issued in early January will require manufacturers of 19 high production volume (HPV) chemicals to test those chemicals and submit the results to the EPA.
The chemicals in question are all in heavy use in the U.S.: HPV chemicals are those that are imported or produced in quantities of greater than 1 million pounds per year. The chemicals are also used in a range of different applications, from personal-care products to blasting and demolition agents.
"This chemical data reporting will provide EPA with critical information to better evaluate any potential risks from these chemicals that are being produced in large quantities in this country," Steve Owens, assistant administrator for EPA's Office of Chemical Safety and Pollution Prevention, said in a statement announcing the rule. "Having this information is essential to improve chemical safety and protect the health of the American people and the environment."
The new HPV rule follows on an HPV Challenge that the EPA issued in 1998 to gather health and environmental data on a voluntary basis from manufacturers; data for the 19 chemicals in question were never submitted.
The EPA did not offer an interview on the subject, directing me instead to the HPV overview page on the EPA website.
But over at EDF's blog, Richard Denison has a clear assessment of just what this new rule will acheive -- and where it falls short:
[T]his rule reveals why it is actually a perfect poster child for what’s wrong with the Toxic Substances Control Act (TSCA).
For starters, consider that it took EPA two and a half years to move the rule from the proposed stage to finalization. And that doesn’t count the several preceding years EPA had to spend developing information sufficient to make the findings it has to make to justify proposing a test rule.
Then consider that the rule addresses only 19 of the many hundreds of HPV chemicals on the market today for which even the most basic, “screening level” hazard data are not publicly available.
[Since this process started,] many hundreds of additional chemicals not included in the original program have reached HPV levels – but without any effective commitment by their makers to develop the base set of hazard data.
All told, Denison writes, it's taken the EPA "more than a decade to be able to impose even minimal testing requirements on just 30 of the many hundreds of HPV chemicals on the market today for which even basic health and environmental data are not publicly available."
Denison makes many more good points about the HPV challenge, as well as what's wrong with chemicals policy in the U.S., in his original blog post. It's well worth a read.
Photo CC-licensed by skycaptaintwo.
Michael Wheeland and Richard
Michael Wheeland and Richard Denison complain that it is taking too long for EPA to impose basic, screening-level testing requirements on HPV chemicals. However, they fail to mention that those testing requirements – pushed through by the Environmental Defense Fund in 1998 – are still largely based on antiquated, animal tests that kill hundreds of animals, cost tens of thousands of dollars and take months to complete.
Under the HPV Chemicals Challenge Program – and test rules such as this one – acute, repeat-dose, reproductive, developmental and in some cases, genetic toxicity must all be tested in animals. In addition, one of the required environmental endpoints is acute toxicity to fish. For each chemical subject to a full battery of tests, approximately 740 animals are killed at a cost of around $70,000. The sub-chronic toxicity tests each take upwards of three months to complete. Multiply these figures by several thousand HPV chemicals and the source of the problem becomes clear. As Joshua Lederberg, Nobel laureate in medicine, once said "it is simply not possible with all the animals in the world to go through new chemicals in the blind way that we have at the present time, and reach credible conclusions about the hazards to human health."
Fortunately, there are faster, better, cheaper – and far less cruel – alternatives. For example, acute toxicity can be studied in vitro with the neutral red uptake (NRU) cytotoxicity test, fish toxicity can be modeled in silico with ECOSAR, and developmental toxicity can be studied using embryonic stem cells.
While the HPV Program continues to look backward to an era of expensive, time-consuming – and inhumane - animal tests that produce irrelevant data, EPA’s ToxCast Program leads the world in implementing 21st-century, high-throughput screening methods that promise for the first time to provide human-relevant data on the thousands of chemicals to which we are exposed. Any discussion of future chemicals policy must embrace this vision, described by the National Academy of Sciences in its report Toxicity Testing in the 21st Century, leading “to a major shift in emphasis away from whole-animal testing toward efficient in vitro tests and greater human surveillance.”
This is good news. Maybe
This is good news. Maybe things will start to change. I am studying residential and commercial textiles right now, and the chemicals in their processing and used as finishes are disgusting! The toxins we produce are mind-blowing. There's one industry that needs an overhaul!