WASHINGTON, DC (February 4, 2014) – The Consumer Specialty Products Association (CSPA) today told members of the House Energy & Commerce Subcommittee on Environment and the Economy that to ensure a risk-based approach under a revised Toxic Substances Control Act (TSCA), more information is needed about downstream chemical uses. This information would be part of the Environmental Protection Agency’s prioritization process envisioned under a revised statute. Testifying on behalf of CSPA, Robert Matthews, an environmental attorney with McKenna, Long & Aldridge LLP, focused on the role downstream formulators could serve under Sections 4 and 8 of the statute.
Matthews said that any screening process developed by EPA should serve to identify chemicals of highest priority for agency review and assessment and it “must be risk-based, taking into consideration a chemical’s hazards and the nature and extent of its uses and potential exposures.” CSPA outlined a set of chemical use-related reporting elements that EPA could get from downstream formulators to better inform the agency’s understanding of exposure potential. Matthews noted that targeted reporting under Section 8 of TSCA would feed into the EPA’s prioritization review and he emphasized the importance of protecting confidential business information and trade secrets provided to the agency during chemical information and use reporting.