Is the current back-pedaling occurring on the Consumer Product Safety Improvement Act as the consequences of quick and overbroad bans on chemicals (lead, phthalates) impact real people and companies of all sizes is there a lesson for TSCA reform? Those who want to loosen the restrictions on EPA to allow easy-pie bans on toxics may find that there is a purpose to honest-to-goodness public notice and comment rulemaking. It may be slow, but it does raise legitimate concerns and shines the light on unintended consequences. Of course, finding the appropriate balance to meet risk management needs is still a political issue of finding consensus and not all parties will be happy. But knee-jerk, low threshold bans will guarantee bad decisions will be made.
16
Dec
2009