Team:UC Davis/Safety



In the United States, the primary legislative framework regarding chemical use is the Toxic Substances Control Act (TSCA), which was passed into law in 1976.
The two main objectives of the law are to:
  1. assess and regulate new commercial chemicals by requiring a premanufacture notice (PMN) listing the chemicals production volume, uses, exposures, and environmental fate, to “the extent it is known to or reasonably ascertainable by the submitter”
  2. regulate the distribution and use of then existing chemicals that pose an, “unreasonable risk to health or to the environment”

This law, though good intentioned, is widely recognized by the U.S. Government Accountability Office, the U.S. Environmental Protection Agency, etc. as ineffective at allowing regulatory agencies to:
  1. assess hazardous traits of a majority of commercial chemicals and to
  2. control chemicals of significant concern.

Wilson et al identified two major flaws with TCSA as follows:
  1. When TCSA was passed into law in 1976, the 62,000 chemicals in commercial use at the time were “grandfathered in” and assumed to be safe unless the EPA could prove otherwise
  2. But in order to assess the risks of existing chemicals, the EPA needed hazard and exposure data that producers were not required to provide (unless the EPA could first show that the substance presented an unreasonable risk to human health or the environment)

This “Catch 22” situation has severely restricted the EPA’s jurisdiction. “In the first 15 years under TSCA, the agency was able to review the risks of about 1,200 (2%) of the 62,000 existing chemicals, despite the fact that the agency estimated that about 16,000 (26%) were potentially of concern based on their production volume and chemical properties”
Indeed, under TCSA the EPA has been unable to regulate even the use of asbestos because the standard of proof to show that a chemical is harmful is so high.
Many agencies are pushing for a reform of this law and in response, the Chemical Safety Improvement Act and the TSCA Modernization Act of 2015 have been drafted, but policy makers remain largely divided on the best way to reform TSCA. As a result, these acts have been stalled in Congress.

Sources:
Lalala
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1. We talked to researchers at the San Francisco Estuary Institute (SFEI), one of California’s premier aquatic and ecosystem science institutes. From researchers at SFEI we learned that there is a need to better understand how chemicals get into our environment as well as their long-term effects (especially on aquatic organism health), but that this is difficult because chemicals are found in many sources and their effects can be insidious/slow acting. Aquatic organisms are particularly at risk because they are constantly subjected to these toxic chemicals – making their exposure more chronic in nature. To manage the risk of triclosan, SFEI is pursuing source control measures. San Francisco Estuary Institutes researchers collect data to assess and improve the health of the waters, wetlands, wildlife, and landscapes of the San Francisco Bay and the California Delta. In 2011, SFEI named triclosan a contaminant of emerging concern and identified the following key information gaps [1]: - the contributions of storm water runoff and municipal waste water as pathways of triclosan to surface waters - the potential chronic effects on algae and microbes due to long term exposure to concentrations of triclosan and other antimicrobials that are typically found in aquatic organisms - the occurrence of degradation and transformation products - the identity, extent of use, and potential environmental health impacts of chemicals used as replacements for triclosan In particular, researchers expressed concern over how most of the toxicity threshold data currently available are from acute effect studies, which are not indicative of the potential effects due to long-term, chronic exposure to concentrations that are typically found in aquatic environments. While environmental levels may seem low, in chronic toxicity studies, effects on the endocrine system in amphibians and the structure and function of algal communities have been observed at concentrations occurring in the environment (Veldhoen et al. 2006; Wilson et al. 2003). More research needs to be done to study the chronic effects. Additional concerns include the potential for indirect effects on algal and aquatic plant grazers due to the toxicity of triclosan to algae and the combined effects of persistent antimicrobial compounds, such as triclosan and triclocarban, on microbial communities. -- Because triclosan is commonly found in consumer products, ECWG’s approach to managing triclosan’s risks is, “encouraging less consumer usage of triclosan-containing antimicrobial hand soaps and other consumer products.”[3] [1] http://www.sfei.org/sites/default/files/general_content/Triclosan_profile_0.pdf [2] http://www.sfei.org/projects/contaminants-emerging-concern-strategy [3]http://www.sfei.org/sites/default/files/biblio_files/RMP2011_TriclosanFactsheet_Final4web.pdf 1. We met with Arlene Blum, director of Green Science Policy Institute, who works to inform companies on the appropriate use of toxic chemicals. Blum provided two key pieces of information: • the need to regulate chemicals as classes • and the influential role industry can play with their purchasing power - CLICK FOR MORE INFO - Blum highlighted the incongruity in evaluating chemical toxicity/risks on an individual basis when chemicals interact with other chemicals – oftentimes synergistically – in the environment. To that end, Green Science Policy Institute categorizes and evaluates chemicals in 6 main classes: highly fluorinated chemicals, flame retardants, bisphenols & phthalates, organic solvents, metals, and antimicrobials. To expound further on the utility of a ‘class’ approach, Blum explained how when chemicals are removed from use, manufacturers look for a replacement; but because these chemicals need to serve similar functions, they often have similar structures, and thus similar consequences. What results is a cycle whereby one toxic chemical is replaced by another toxic chemical. Blum aims to stop this cycle and reduce the overall use of toxic chemicals in consumer products by targeting the elimination of these classes of chemicals where there use has no proven benefit. Blum affirmed that policy change through government is often slow and mentioned that a quicker, more effective, way to bring about change is if key players in industry take action. By electing to phase a chemical out of their products, industry can have an enormous influence on the types and amount of chemicals that are released into our environment. At Green Policy Institute, Blum works to inform manufacturers, retailers and consumers about where these classes of chemicals can be found, how they can be avoided, and what alternatives might be available. This approach has proven effective: Green Science Policy Institute provided much of the data that was instrumental in persuading furniture manufacturers to reduce their use of flame-retardants and in persuading policy makers to revise state furniture flammability standards. source 3. We talked to Bruce Hammock, a National Academy Member for his work in environmental toxicology. Has authored # of papers on triclosan, and is largely responsible for raising awareness about triclosan/putting triclosan on the map. Hammock talked about how there are appropriate and inappropriate uses for chemicals, and that for even triclosan, a chemical that he has authored # papers on, Even Hammock, who has authored ___ papers on the ___ of triclosan, mentioned that triclosan is not all bad. urged for the more prudent usage of chemicals – stating that the context of application is really important in determining when a chemicals use is appropriate. To illustrate this, Hammock talked about how triclosan actually plays a very useful role in surgical scrubs by removing the last 1% of bugs that soap won’t remove but that this extra bit of killing power is not needed in everyday use. 4. We talked to Jonathan Eisen, ____ who studies microbial communities. Doesn’t like how triclosan is embedded in building products Questions if triclosans use in commercial products is justified. We don't know enough about harmful effects but are putting them in anyways. Wrong approach. Instead, should justify a chemicals use before putting it into products. Summary: From talking to experts, we concluded that its hard to track and monitor the spread of chemicals because chemicals are found in a range of products and make their way into the environment through a variety of routes. In the environment, chemicals interact with one another – oftentimes synergistically. Aquatic organisms are particularly at risk because of their chronic exposure to toxic chemicals. To more effectively manage risks experts are pursuing the following measures: - regulating chemicals by class instead of on an individual basis - source control at the consumer and industry level And have expressed the need for: - raising awareness around appropriate use - and justifying the use of these chemicals in products
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Testing testing testing

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