Demanding health-protective implementation of TSCA
EDF comments and blogs on 10 key aspects of TSCA implementation
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)
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.