Because of the Environmental Protection Agency's (EPA) limited ability to mandate testing under the old Toxic Substances Control Act (TSCA), which was recently overhauled, Environmental Defense Fund impelled the chemical industry to agree voluntarily to develop basic hazard information on so-called high production volume (HPV) chemicals — those produced in amounts exceeding one million pounds annually.
Through our 1997 report "Toxic Ignorance" [PDF], we raised public awareness of how few HPV chemicals had been tested and how little data were available to the public. In response, the voluntary HPV Challenge was launched in 1998 to close the data gaps and give the public access to basic hazard information on 2,200 chemicals produced and used in the largest amounts.
EDF closely monitored the Challenge every step of the way, tracking its progress in a series of reports and via our online HPV Tracker, and documented what it did—and did not—accomplish. Our final assessment, "High Hopes, Low Marks: A final report card on the HPV Challenge" revealed some accomplishments but also serious limitations to this voluntary approach.
We also watch-dogged EPA's next step in its process to assess the HPV chemical data and address chemicals in commerce. In March 2008, EPA announced ChAMP (Chemical Assessment and Management Program) as the U.S. answer to the European Union's REACH Regulation, as well as other global efforts to advance knowledge about chemicals and manage their risks.
As assessments of HPV chemicals began to be published under ChAMP, EDF identified major problems with the data, especially those characterizing chemical use and exposure, on which EPA was relying. We first raised our concerns in comments and analysis [PDF] we provided to EPA in 2008. See also our news release "ChAMP just doesn't have the REACH" (May 2008).
When these concerns went largely unaddressed, we began to use our blog to publish an overview of our critique of ChAMP and to document the problems through a series of analyses of specific ChAMP assessments:
We also proposed ways that ChAMP (or its successor) could get back on track.
In June 2009, EPA announced it was suspending ChAMP, and in October, announced it was scrapping ChAMP and replacing it with an enhanced chemicals management program. EDF strongly supported the enhancements, which shifted the focus from endless testing and assessment to identifying and taking action to reduce exposure to high-concern chemicals.