A platform for reform of the Toxic Substances Control Act

A reformed Toxic Substances Control Act (TSCA) would serve as the backbone of a sound and comprehensive chemicals policy that protects public health and the environment, while restoring the luster of safety to U.S. goods in the world market. Any effective reform of TSCA should:

  • Immediately Initiate Action on the Worst Chemicals: Persistent, bioaccumulative toxicants (PBTs) are uniquely hazardous. Any such chemical to which people could be exposed should be phased out of commerce. Exposure to other toxic chemicals, such as formaldehyde, that have already been extensively studied, should be reduced to the maximum extent feasible.
  • Require Basic Information for All Chemicals: Manufacturers should be required to provide basic information on the health hazards associated with their chemicals, how they are used, and the ways that the public or workers could be exposed.
  • Protect the Most Vulnerable: Chemicals should be assessed against a health standard that explicitly requires protection of the most vulnerable subpopulations. That population is likely to usually be children, but it could also be workers, pregnant women, or another vulnerable population.
  • Use the Best Science and Methods: The National Academy of Sciences' recommendations for reforming risk assessment at the Environmental Protection Agency (EPA) should be adopted. Regulators should expand development and use of information gleaned from “biomonitoring,” the science of detecting human chemical contamination, to inform and impel efforts to reduce these exposures.
  • Hold Industry Responsible for Demonstrating Chemical Safety: Unlike pharmaceuticals, chemicals are currently presumed safe until proven harmful. The burden of proving harm falls entirely on EPA. Instead, chemical manufacturers should be responsible for demonstrating the safety of their products.
  • Ensure Environmental Justice: Effective reform should contribute substantially to reducing the disproportionate burden of toxic chemical exposure placed on people of color, low-income people and indigenous communities.
  • Enhance Government Coordination: The EPA should work effectively with other agencies, such as FDA, that have jurisdiction over some chemical exposures. The ability of the states to enact tougher chemical policies should be maintained and state/federal cooperation on chemical safety encouraged.
  • Promote Safer Alternatives: There should be national support for basic and applied research into green chemistry and engineering, and policy should favor chemicals and products that are shown to be benign over those with potential health hazards.
  • Ensure the Right to Know: The public, workers, and the marketplace should have full access to information about the health and environmental hazards of chemicals and the way in which government safety decisions are made.