CSPA is committed to engaging with all stakeholders to provide input on legislation that will direct how chemicals in commerce are regulated under the Toxic Substances Control Act 1976 (TSCA). CSPA member companies believe that TSCA should be updated to recognize the changes in science and technology during the past four decades. A modernized federal chemical management statute will: (1) create a more predictable regulatory environment for product manufacturers; (2) reduce continued actions at the state level and actions by several large retailers to establish chemical management programs; and (3) improve public confidence and trust in the safety of chemicals used in everyday products.
Ensuring the safety of products while maintaining the confidence of consumers is the single most important goal of the household and institutional products industry. Product safety is the foundation of consumer trust, and our industry devotes enormous resources to ensure both the safety and safe use of our products.
CSPA has worked to establish and maintain sound working relationships with Republicans and Democrats in the U.S. House of Representatives and Senate, the U.S. Environmental Protection Agency (EPA), industry groups and non-government organization (NGO) stakeholders involved in the efforts to modernize TSCA. CSPA directly engages member companies in these discussions through its Federal Government Affairs Advisory Committee (GAAC) and the Chemical Management Policy Team (CMPT). In addition, CSPA participates actively in congressional working sessions and other TSCA work groups to leverage ongoing opportunities to educate decision makers on the regulatory impacts and challenges that should be considered in any legislative action to update TSCA. These discussions have helped break down barriers of disagreement and lead to common ground that will help address complex technical legislative issues.
CSPA supports the following policy challenges under TSCA:
- Exposure and Use Information. Congress should work with the consumer products industry and others to determine the best approach under TSCA for the EPA to obtain adequate and timely information on chemical use and exposure that is needed for the prioritization and assessment of chemicals. The process should allow EPA to apply streamlined data collection approaches to obtain additional data and information with which to better inform Agency decisions.
- Setting Priorities. Congress should direct EPA to identify “priority” substances for further safety assessment. This should be done through a prioritization system that will include appropriate and transparent criteria to rank order how chemicals should proceed through the assessment process. Both human and environmental safety should be addressed in the prioritization of a chemical substance, including risk a chemical may pose to sensitive populations. Congress should examine how industry studies that meet EPA protocols and procedures can be used to support these objectives.
- Deadlines. Congress should consider how to establish clear and achievable deadlines for the review of priority chemicals, and should ensure that EPA has adequate resources to meet these deadlines. Congress also should explore ways to leverage reviews by Canada, the European Union and other nations with modern product safety systems to avoid duplicative and wasteful testing.
- Innovation. Congress should ensure that improvements to TSCA promote―and not hinder―innovation and new product development. This is important to support a shared goal of maintaining global competitiveness for U.S. producers and users of chemicals. Continuous innovation is a critical element for expanding the U.S. economy, and meeting new environmental and sustainability challenges, such as those adopted under the CSPA Product Care® and the EPA Design for the Environment (DfE) program. Protecting confidential business information and clarifying the roles of the states will foster greater investment in innovation and generate growth needed for U.S. companies to compete in the global marketplace.
CSPA, led by the active involvement of its member companies in the Federal GAAC and the CMPT, is committed to working with Congress and all stakeholders on these issues in legislative proposals to update TSCA.