The Society of Chemical Manufacturers and Affiliates (SOCMA), in a statement submitted to the US Senate Subcommittee on Superfund, Toxic and Environmental Health, provided support for a bipartisan review of the Toxic Substances Control Act (TSCA) as that subcommittee considers reforming the chemical-control law. SOCMA is a trade association representing custom and batch manufacturers, including contract manufacturers of active pharmaceutical ingredients, pharmaceutical intermediates, and other fine and specialty chemicals.
“SOCMA understands that TSCA modernization is a complex issue that deserves close scrutiny,” said SOCMA President Lawrence D. Sloan in a SOCMA Feb. 3, 2011, press release. “Many relevant factors should be considered, most of which, we believe, fall outside the statute itself.”
Sloan said that TSCA's critics selectively cite chemical statistics that paint an incomplete picture of TSCA’s effectiveness. He underscored the fact that these statistics alone make it appear as if TSCA has failed due to a relatively low number of restricted chemicals, but contended that a great deal of testing is conducted. He added that most chemicals can be used safely and therefore do not require additional restrictions. Sloan noted that there are many other federal laws that govern chemicals management and that advances in the field of analytical chemistry should be acknowledged before “placing blame solely on TSCA for increased exposures,” according to the SOCMA release.
SOCMA asked the subcommittee to consider various metrics to evaluate TSCA before introducing new legislation, such as the following:
- The number of new chemicals reviewed by the Environmental Protection Agency under Section 5 since TSCA’s inception
- The number of Pre-Manufacturing Notices (PMN) that were withdrawn as a result of those reviews
- The number of PMNs for which review periods were voluntarily suspended while the submitter conducted tests or gathered other data
- The number of Significant New Use Rules (SNURs) issued by EPA
- The number of existing chemicals actually in commerce.
“Ultimately, success will not depend solely or primarily on how many chemicals are restricted, but on the net health, environmental, and economic effects of implementing these laws,” Sloan said in the release.
SOCMA said it will continue its efforts to promote recommendations for a “pragmatic approach” to TSCA modernization with members of Congress. On Apr. 13, 2011, SOCMA members will discuss their position with lawmakers and their staff during the association’s annual Washington Fly-In.