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TSCA and the Chemical Evaluation Process

Posted by Kathy Attar, MPH on December 7, 2016

Under the new Toxic Substances Control Act (TSCA), the federal law that regulates industrial chemicals, EPA has announced the first ten harmful chemicals to be evaluated for risks to human health and the environment.

The new TSCA requires chemical evaluations be completed within three years. If EPA decides that a chemical presents an "unreasonable risk", EPA must put in place restrictions such as bans or labeling requirements, within two years. The process to get these toxic chemicals off the market will be slow.

The chemicals on the EPA's list pose serious health concerns to consumers and workers. Further, there is significant evidence that exposure to them is occurring right now. Many are found in consumer products and have been linked to cancer as well as reproductive, developmental and neurological toxicity.

EPA's first 10 harmful chemical list:

  • Trichloroethylene (TCE) is a known human carcinogen. Used to dry-clean clothes and as an industrial degreaser in consumer, commercial, and industrial products.
  • 1, 4 dioxane is a likely carcinogen can be found in personal care products like shampoo. We can also be exposed to 1, 4 dioxane in dyes, varnishes and waxes.
  • Tetrachloroethylene (PERC) is a probable carcinogen. Used as a dry-cleaning fluid and in water repellents, spot removers, wood cleaners, adhesives and silicone lubricants.
  • 1-bromopropane is a possible carcinogen and reproductive toxin. It is used in aerosol cleaners, adhesives and spot removers and for a variety of industrial applications. Certain dry-cleaning processes may also use 1-bromopropane. Pregnant women are particularly susceptible as even small exposures can be harmful to the developing fetus.
  • Asbestos is a known carcinogen. Most people believe it is banned; it is not. Asbestos can still be used in insulation, brake pads, vinyl tiles and roofing materials.
  • Methylene chloride is a probable carcinogen. Used as a paint stripper. It may also be found in spray paint and adhesives and in the manufacturing of photographic film.
  • HBCD is a potential reproductive, developmental and neurological toxin. HBCD is a flame retardant used in polystyrene foam, textiles, and electronics. It is also found in building materials such as insulation.
  • N-methyl-2-pyrrolidone is a reproductive toxin. Used in paint and coating-removal products, and as a cleaning agent for electronics and in industrial/domestic cleaning.
  • Pigment Violet 29 is toxic to aquatic animals. It is a dye widely used in automotive and other coatings and plastics.
  • Carbon tetrachloride is a probable carcinogen. This chemical poses a greater risk to workers as it is primarily used as a solvent in commercial and industrial products to make propellants, among other industrial chemicals.

This list scratches the surface of the hundreds of harmful chemicals already on the market that need evaluation and then swift action to rid them from our products and communities. Further, EPA's initial list leaves out a major offender: lead. Lead, a known neurotoxin, can still be used in products such as wheel weights and jewelry, among others. Children, often low-income and children of color, suffer the greatest and most long-lasting health risks from lead exposure.

The new TSCA law could be an opportunity to reduce health risks for consumers and workers. Unfortunately, under the incoming Trump administration, how chemical risk assessments are performed could be negatively influenced by industry. This could lead to chemicals being given the green light despite clear health and exposure risks.

Myron Ebell, who is heading Trump's EPA transition team, is a long-time climate change denier. He also works at the Competitive Enterprise Institute. The Institute houses a "SafeChemicalPolicy.org" project which writes reports that generate uncertainty about the dangers of toxic chemicals in our environment. For example, they downplay the health risks associated with arsenic in drinking water and the need to tighten the U.S. drinking water standard. Arsenic has been linked to a number of cancers.

Health and environmental organizations must continue to watchdog the implementation of the new TSCA. We will draw contrasts between actions that protect public health and those that threaten our health and safety. We'll be particularly vocal on behalf of those most susceptible—pregnant women and children--and most exposed-- communities of color, low-income folks and workers.

Comments

Daniel Kerlinsky MD said ..

A retired Air Force firefighter in my practice and a retired pesticide sprayer educated me about the government collusion and cover-up of toxic chemical uses... that have always been far outside - in practice - the boundaries of alleged protection. Halons have been cherished by the Air Force for high pressure hydraulic lines in Air Force jets and missiles. Can't we make the connection to a pivotal role for halons in running high-pressure fracking equipment? PSR deserves credit for the recent health compendium report on fracking. And we can't budge the Air Force from using halons to spray circuit boards in advanced weapons systems. Nor can we stop the use of halon fire extinguishers wherever a room full of computers is gathered in the military or any commercial business setting. Teaching fire-extinguishing in pit fires created toxic halon gas exposure that penetrated through protective equipment. And ordinary home and office pesticide spraying would cost $500 instead of less than $50 if the proper precautions were taken. You ought to see the tissue degeneration that deforms people working in these toxic professions - total body edematous degeneration that makes muscle, connective tissue, and bone feel like mush - extremely painful mush. Thanks to Arnold Schechter and ATSDR for the education I got in the years of working with the Environment and Health committee of PSR. The facts are so much worse when you see the horror of advanced illness in patients we find in our offices. The one thing physicians fail on -again and again - is to palpate the patients to feel directly what toxic chemicals do to the body and brain. Palpate - and you can feel stiffness in the lungs, and frontal lobes and liver. Palpate and you can feel the chronic heat and sponginess of connective tissue and intestinal walls. Palpate - and then you will know what questions to ask to try to find the source of toxic chemical exposure.

April 8, 2017

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