Demanding health-protective implementation of TSCA

On June 22, 2016, President Obama signed the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which substantially amended the Toxic Substances Control Act (TSCA) to create a stronger and more effective chemical safety system in the United States.

In the face of the Trump Administration and industry pressure to weaken TSCA implementation, EDF worked hard to demand that EPA effectively implements the strengthened TSCA and fulfills its duties to protect the American people from harmful chemicals. Below is a repository of the many comments EDF has submitted to EPA and our blog posts on 10 key components of TSCA implementation:

• Pre-market reviews of new chemicals
• Risk evaluation rule
• Prioritization rule
• Inventory notification rule
• Fee rule
• First 10 chemicals undergoing risk evaluations
• Systematic review
• Alternatives to vertebrate animal testing
• Chemical-specific risk management
• Public access to chemical information and Confidential Business Information (CBI)

Case resources for Lautenberg Act implementation

Pre-market reviews of new chemicals

EPA documents

• New Chemicals Decision-Making Framework

  Published November 5, 2017

EDF comments

• Comments on EPA's implementation of changes to New Chemicals Program and its New Chemicals Decision-Making Framework

  Submitted January 20, 2018

• Comments supporting initial changes to New Chemicals Program

  Submitted January 17, 2017

EDF blog posts

• The Trump EPA is throwing workers fating risk from new TSCA chemicals under the bus (3-part series)

  Published February 21 – April 3, 2019

• EDF files extensive comments challenging EPA's changes to new chemical reviews under TSCA

  Published January 22, 2018

• All EDF blog posts on new chemicals

Risk evaluation rule

EPA documents

• Final rule

  Published July 20, 2017

• Proposed rule

  Published January 19, 2017

EDF comments

• Comments on EPA's proposed rule

  Submitted March 20, 2017

• Comments preceding EPA's proposed rule

  Submitted August 24, 2016

EDF blog posts

• EDF joins Opening Brief in legal challenge to EPA’s Prioritization and Risk Evaluation Rules

  Published April 17, 2018

• Final TSCA framework rules retreat from best available science

  Published June 29, 2017

• Getting the framework right for the new TSCA: EDF comments filed on key EPA proposed rules

  Published March 21, 2017

• EDF files comments on three TSCA rules EPA is developing

  Published August 25, 2016

Prioritization rule

EPA documents

• A Working Approach for Identifying Potential Candiate Chemicals for Prioritization [PDF]

  Published September 27, 2018

• Discussion Document: Possible Approaches and Tools for Identifying Potential Candidate Chemicals for Prioritization [PDF]

  Published November 13, 2017

• Final rule

  Published July 20, 2017

• Proposed rule

  Published January 17, 2017

EDF comments

• Comments on working approach

  Submitted November 15, 2018

• Comments on discussion document

  Submitted January 25, 2018

• Comments on EPA’s proposed rule

  Submitted March 20, 2017

• Comments preceding EPA’s proposed rule

  Submitted August 24, 2016

EDF blog posts

• The Trump EPA is poised to grant the chemical industry yet another of its wishes under TSCA

  Published November 16, 2018

• EDF joins Opening Brief in legal challenge to EPA's Prioritization and Risk Evaluation Rules

  Published April 17, 2018

• EDF files comments on EPAs approaches to the process under TSCA formerly known as pre-prioritization

  Published January 29, 2018

• Final TSCA framework rules retreat from best available science

  Published June 29, 2017

• Getting the framework right for the new TSCA: EDF comments filed on key EPA proposed rules

  Published March 21, 2017

• EDF files comments on three TSCA rules EPA is developing

  Published August 25, 2016

Inventory notification rule

EPA documents

• Final rule

  Published August 11, 2017

• Proposed rule

  Published January 13, 2017

EDF comments

• Comments on EPA's proposed rule

  Submitted March 14, 2017

• Comments preceding EPA's proposed rule

  Submitted September 16, 2016

EDF blog posts

• EDF files Opening Brief in legal challenge to EPA’s Inventory Notification Rule

  Published March 7, 2018

• Known knowns and known unknowns: Getting an accurate, transparent and up-to-date TSCA chemical inventory

  Published March 29, 2017

• Separating fact from fancy in the TSCA Inventory reset mandated by the Lautenberg Act

  Published October 7, 2016

Fee rule

EPA documents

• Proposed rule

  Published February 26, 2018

EDF comments

• Comments on EPA’s proposed rule

  Submitted May 24, 2018

• Comments preceding EPA’s proposed rule

  Submitted August 24, 2016

EDF blog posts

• EPA seriously underestimates its costs under TSCA and lowballs industry fees as a result

  Published May 25, 2018

First 10 chemicals undergoing risk evaluations

EPA documents

• EPA draft risk evaluation for Pigment Violet 29

  Published November 2018

• Proposed asbestos significant new use rule (SNUR)

  Published June 11, 2018

• EPA webpage for first 10 chemicals

EDF comments

• Comments on materials supporting risk evaluation for Pigment Violet 29

  Submitted May 17, 2019

• Comments on draft risk evaluation for Pigment Violet 29

  Submitted January 14, 2019

• Comments on EPA's proposed asbestos SNUR

  Submitted August 10, 2018

• Comments on EPA's problem formulations for first 10 chemicals

  Submitted August 16, 2018

• Comments on EPA’s draft scopes for first 10 chemicals

  Submitted September 19, 2017

• Comments preceding EPA's draft risk evaluation scopes for first 10 chemicals

  Submitted March 15, 2017

EDF blog posts

• The Trump EPA's first TSCA risk evaluation is an epic fail

  Published January 15, 2019

• How Pruitt's EPA finds a dangerous chemical is safe: Ignore most exposures to it

  Published July 5, 2018

• Pruitt's EPA plans to systematically deconstruct the expanded authority a bipartisan Congress gave it less than two years ago

  Published April 3, 2018

• EDF files extensive comments critical of EPA's problem formulations for the first 10 chemicals being reviewed under TSCA

  Posted August 17, 2018

• All EDF blog posts on Pigment Violet 29

Systematic review

EPA documents

• Application of Systematic Review In TSCA Risk Evaluations [PDF]

  Published May 2018

EDF comments

• Comments on EPA’s systematic review document

  Submitted August 16, 2018

EDF blog posts

• EDF submits extensive comments critical of EPA OPPT's TSCA systematic review document

  Submitted August 17, 2018

Alternatives to vertebrate animal testing

EPA documents

• Final strategic plan [PDF]

  Published June 22, 2018

• Draft strategic plan

  Published March 7, 2018

EDF comments

• Comments on draft strategic plan

  Submitted May 15, 2018

• Comments preceding EPA's draft strategic plan

  Submitted January 10, 2018

Chemical-specific risk management

Tricholoreothylene

EPA documents

• Proposed rule to ban TCE in vapor degreasing

  Published January 19, 2017

• Proposed rule to ban TCE in aerosol degreasing and spot cleaning agent in commercial dry cleaning

  Published March 16, 2017

EDF comments

• Comments supporting proposed rule to ban TCE in vapor degreasing

  Submitted May 19, 2017

• Comments supporting proposed rule to ban TCE in aerosol degreasing and spot cleaning agent in commercial dry cleaning

  Submitted March 16, 2017

EDF blog posts

• Families speak out on trichloroethylene exposure: It's time for EPA to act on TCE

  Published August 1, 2018

• Systematic slowdown: EPA indefinitely delays virtually all proposed actions to restrict chemicals under TSCA

  Published December 20, 2017

• EPA's ban on high-risk uses of trichloroethylene needs to get over the finish line

  Published March 31, 2017

• EPA proposes second rule to ban more uses of toxic TCE

  Published January 12, 2017

Methylene chloride and N-methylpyrrolidone

EPA documents

• Advanced notice of proposed rulemaking (ANPRM) for a commercial training, certification, and limited access program for methylene chloride

  Published March 27, 2019

• Final rule banning consumer use of methylene chloride paint strippers

  Published March 27, 2019

• Proposed rule to ban/restrict DCM and NMP in paint and coating removal products

  Published January 19, 2017

EDF comments

• Comments opposing ANPRM for a commercial training, certification, and limited access program for methylene chloride

  Submitted May 28, 2019

• Comments requesting ban on methylene chloride in paint and coating removal products in the furniture refinishing sector

  Submitted November 12, 2017

• Comments supporting proposed rule to ban DCM and NMP in paint and coating removal products

  Submitted May 19, 2017

EDF blog posts

• Long-delayed methylene chloride ban finalized but still leaves workers at risk

  Published March 15, 2019

• Methylene chloride in paint strippers: A ban is the only health-protective path forward

  Published May 15, 2018

• Systematic slowdown: EPA indefinitely delays virtually all proposed actions to restrict chemicals under TSCA

  Published December 20, 2017

• Another tragic death – time for EPA to ban high-risk chemical paint strippers

  Published June 5, 2017

• On a roll: EPA proposes to ban or restrict two highly toxic paint stripping chemicals

  Published January 13, 2017

Persistent, Bioaccumulative and Toxic Chemicals

EPA documents

• Human Health and Environmental Summary for Five PBT Chemicals

  Published June 18, 2018

• Exposure and Use Assessment for Five PBT Chemicals

  Published June 18, 2018

EDF comments

• Comments on Exposure and Use Assessment and Human Health and Environmental Hazard Summary for Five PBT Chemicals

  Submitted August 17, 2018

• Initial comments on five PBT chemicals

  Submitted January 12, 2018

EDF blog posts

• EDF submits comments for peer reviewers on EPA’s exposure, use and hazard information on five PBT chemicals

  Published July 24, 2018

Public access to chemical information and Confidential Business Information (CBI)

EPA documents

• Final guidance for obtaining access to CBI

  Published June 2018

  • State, local and tribal governments [PDF]
  • Medical and environmental professionals in non-emergency situations [PDF]
  • Emergency responders [PDF]

• Final Unique Identifier Approach

  Published June 27, 2018

• Unique Identifier Proposals I & II

  Published May 8, 2017

• Unique Identifier Proposal III

  Published February 8, 2018

EDF comments

• Comments on Unique Identifier Proposals I & II

  Submitted July 7, 2017

• Comments on Unique Identifier Proposal III

  Submitted March 12, 2018

• Comments on proposed guidance for obtaining access to CBI

  Submitted April 15, 2018

• Other EDF blog posts on information access and CBI

See also sections above on the new chemicals and inventory notification rule, which include CBI issues.