Comments to EPA on TSCA Chemicals Regulation
The Environmental Protection Agency (EPA) is proposing to regulate four chemicals that have serious environmental and health risks. We submitted comments supporting EPA and suggesting ways the agency can strengthen its proposal and, additionally, urging EPA to reexamine its decision not to regulate a fifth chemical.
The Toxic Substances Control Act (TSCA) requires EPA to take expedited action to reduce exposure to the chemicals at issue in this proposal. EPA’s proposal focuses on the qualitative benefits of regulating four chemicals that have a variety of uses, including as fire retardants, plasticizers, fuel additives, and rubber manufacture components. Our comments explain how quantifying those benefits would strengthen the proposal. Where it is not possible for EPA to monetize benefits within the required timeframe, the agency should consider conducting a breakeven analysis to facilitate the public’s understanding of the rule’s impacts. We also urge EPA to reexamine its proposal not to regulate the fifth chemical, hexachlorobutadiene (HCBD). HCBD poses serious health risks, including genotoxicity, neurological damage, developmental and reproductive harm, cancer, and premature mortality. And EPA has not provided an adequate analysis or a reasoned explanation for the decision not to regulate HCBD.