Thousands of Chemicals on the Market But No Rules to Test for Safety
It has been 37 years since Congress passed the Toxic Substances Control Act (TSCA) which was intended to ensure the safety of industrial chemicals. Ask anyone familiar with this law and they will tell you that it is an antiquated and toothless law statute that has failed to protect the public from the dangerous effects of exposure to harmful chemicals.
The current law allows new chemicals to be introduced into commerce with minimal testing, gives a pass to the 62,000 chemicals already on the market when the bill was adopted in 1976, and puts up so many roadblocks to taking a chemical off the market that EPA hasn’t tried to do it in over 20 years.
Since TSCA’s passage, rates of serious diseases like breast cancer, prostate cancer, Parkinson’s, learning disabilities and other health conditions have increased —not decreased -- as one might expect if the law were in fact health protective.
Today, there are over 80,000 chemicals on the TSCA registry and fewer than 10% of these have ever been tested for their effects on human health. But even these few tests are outdated. The tests usually focus on the effect of one chemical exposure at a time on the average adult.
We know that this is not how exposure happens.
Humans are exposed to multiple chemicals at a time in a myriad of conditions at all stages of our lives. For example, workers and those living near polluting facilities likely encounter higher exposures than individuals working and living in less polluted settings. Similarly, young children, pregnant women, and others likely have vulnerabilities that our current toxicity testing does not take into account.
For instance, we now know that the prenatal environment is not the pristine place that we had once imagined. Chemicals can cross the placental barrier and alter fetal development. A recent report (go to www.breastcancerfund.org to view the report) released by the Breast Cancer Fund aggregated the science on one chemical, bisphenol A, and showed that it not only entered into the prenatal environment but that it also was significantly altering fetal development in a way that could increase risk for later life diseases like cancer. Even the nation’s leading association of OBGYNs recently released a statement (go to www.acog.org to view the statement) calling for better testing of chemicals and restrictions on those that can harm the developing fetus.
We also know that people are not exposed to one chemical at a time in a vacuum. Rather, we are exposed to a mixture of hundreds of chemicals alongside other environmental stressors that can alter how our bodies respond to these exposures.
In 2007 and 2008, the National Academy of Sciences (NAS) weighed in on chemical testing and also found that the current methods of toxicity testing were woefully outdated. The NAS provided a series of recommendations that would take real world exposure scenarios into account. The recommendations include incorporating prenatal exposure when assessing chemical risks as well as assessing unique vulnerabilities that may be present in human populations. The NAS separately issued recommendations on how to cost effectively screen tens of thousands of chemicals, while also minimizing animal testing.
When the late Senator Frank Lautenberg introduced the Safe Chemicals Act in 2013, his bill explicitly required that chemical testing standards be updated to reflect the NAS recommendations.
However, the current legislation before Congress, the Chemical Safety Improvement Act (CSIA), noticeably omits any reference to the NAS recommendations and only briefly mentions concepts like vulnerable populations.
Without explicit language directing the EPA to incorporate these recommendations when developing tests for chemicals, our health will continue to be adversely impacted by outdated and ineffective ways of evaluating chemicals.
Scientific understanding about chemicals has evolved in 37 years. We now know that chemicals can alter our bodies’ normal hormonal functions at exquisitely low doses. We know that chemicals can work in combination with each other to have a greater impact than they would have had alone. And we know that the timing of a chemical exposure can mean the difference between no effect and big impacts.
We cannot simply put our heads in the sand and pretend that these facts are not true. The NAS recommendations are a critical piece of any chemical safety law to ensure that our chemical regulatory system follows the best available science and that it truly protects everyone.
As the Congress considers possible changes to toxics legislation, getting the science right about the impact of chemicals on human health should rank among its top priorities.
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