ChAMP Just Doesn't Have the REACH

May 2, 2008



Sharyn Stein,, 202-572-3331

Richard Denison,, 202 387-3500

(Washington, DC – May 2, 2008) – A set of mostly voluntary initiatives recently announced by the U.S. Environmental Protection Agency (EPA) to identify and manage the risks of thousands of chemicals will provide far less protection than the more comprehensive approach taken under the European Union’s new REACH Regulation, according to Environmental Defense Fund (EDF). 

EDF is presenting its critique of EPA’s Chemical Assessment and Management Program (ChAMP) at a meeting being held today by EPA to receive input on its initiatives.

“ChAMP just doesn’t have the reach of REACH, despite EPA’s efforts to claim otherwise,” said Dr. Richard A. Denison, EDF Senior Scientist.  “It will yield far less data on far fewer chemicals.  In its haste to catch up with other global initiatives, EPA intends to make decisions about risk using incomplete or poor quality information, especially with respect to how chemicals are used and how people and the environment are exposed to them.”

EDF noted that many of ChAMP’s shortcomings can be directly traced to structural deficiencies in the authority EPA has been provided under the Toxic Substances Control Act (TSCA), the main U.S. statute that governs how tens of thousands of chemicals are produced, used and disposed of.  “EPA’s ability to require data to be developed that are sufficient to conduct a robust assessment of a chemical’s risks is highly constrained under TSCA”, Denison said.  “That’s why it is now proposing yet more voluntary initiatives, even though EPA’s recent voluntary programs have received low marks.”

“EPA’s authority to take action to control a chemical found to be dangerous is even more constrained,” Denison added. “Perhaps that’s why under ChAMP, the next step EPA is proposing for chemicals it finds are high-concern risk priorities is merely to ‘encourage companies to provide available information on a voluntary and non-confidential basis.’   The limitations of ChAMP we’ve identified are a great illustration of why EPA needs much broader authority to identify and control dangerous chemicals.  EDF is calling for a major overhaul of TSCA, which has not been amended appreciably since its adoption 32 years ago. EPA should join in that call.”

EDF’s analysis identified a number of additional shortcomings of ChAMP:

  • A lack of transparency in describing what information EPA possesses and relies on to judge the likelihood of exposure to the chemicals it is assessing;
  • Failure to initiate steps to fill the gaps in safety data EPA has identified, and to compel testing of chemicals whose manufacturers have not volunteered to develop the needed data;
  • Significantly overstating the number of high-volume chemicals for which EPA has data necessary to conduct screening-level hazard and risk characterizations; and
  • Reliance on information provided by manufacturers on how a chemical is used even when other available information indicates additional uses that could cause greater exposure.

“While there are serious shortcomings in many of EPA’s initiatives, there are also some positive aspects,” said Denison.  “EPA’s proposal to screen medium production volume chemicals and prioritize them for further action based on their hazards is a welcome expansion of EPA’s efforts to date.  And the proposal to publicly identify chemicals EPA finds could pose a significant risk will help chemical users, workers, consumers and the public to demand safer alternatives.”

EDF’s full analysis of ChAMP and other recent analyses of chemicals policies in the U.S. and other jurisdictions are available here.