EPA is holding a webinar on how they are going to prioritize chemicals under TSCA Sept 7, 2011, 1:30 - 3:30 pm EST. Register here.   Apparently they heard the message that their picks of chemicals of concern for "action plans" were pretty random.  Will this be a recast of ChAMP?

Get background and blog on the topic with EPA here until Sept 14.  This seems more a focus on data sources than the actual assessment and prioritization process itself, however.  The devil is always in the detail and weighting of factors and just how large a collection of chemicals EPA intends to tackle and how.

Once upon a time, I helped develop a model with the then Chemical Manufacturers Association on how EPA could prioritize chemicals based on a separatory funnel filled with red, yellow and green chemical-application entities (represented by jelly beans in an actual sep funnel).

(c)1996, Chemical Maufacturers Association Product Risk Management Strategy Overview

We argued that EPA should focus on the highest likely risks (worst first) - the red chemical-application/use combinations (red dots).  The factors EPA lists in the background paper are "red," although it's not clear they are talking risk as in exposure + toxicity, rather than stand alone criteria: children's products, PBT, developmental effects, carcinogens.  But key to the concept of the sep funnel was that EPA should titrate (tackle) red dots (high potential risk chemical-applications) only at the rate it could manage through its regulatory processes.  As it screened and addressed chemical risks, it could  titrate out some more chemical-use applications.  Of course, the Jackson EPA is into issuing blacklists of chemicals and publishing industry reported data (the new CDR with difficult CBI claims) to enable NGOs to exert pressure on companies to eliminate chemical use, so EPA can avoid writing regs.

We even went so far as to draft the reporting elements of a "red dot reporting rule" - focused on toxic  chemicals that would likely be highest risks according to exposure filters.  At that time (mid-90's), we were trying to avoid threatened massive IUR reporting. Fifteen years later, we get the Chemical Data Reporting Rule - without the filters, so we'll have a lot of yellow and green chemical dots being reported on - with EPA still not sure how it's going to prioritize chemicals.  Sigh....


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