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The Sierra Club recommends the following improvements to the Chemical Safety Improvement Act to protect the health of workers, the public, and the environment and to foster an innovative chemical industry that supports middle class jobs:

  • Protecting Vulnerable Populations: In making safety assessments and safety determinations, EPA must be required to account for heightened health risks borne by particular populations. Whether due to biology, or to aggregate or cumulative exposures, many groups including children, pregnant women, workers with occupational exposure to chemicals, and residents of highly contaminated "hotspot" communities should be explicitly included in a definition of 'vulnerable subpopulations.' Additionally, the question of how EPA can use unreasonable risk as a health-only based safety standard must be addressed.
  • Preserving State Authority: This bill's federal preemption provisions are too broad, disallowing state action on chemicals upon EPA designation as 'high priority' or 'low priority.' Compounding this, the bill's requirements for receiving a preemption waiver are set too high. Concern has already been expressed at the California Department of Toxic Substances Control that the bill would impair their ability to ensure public safety. State authority to regulate above a floor created by federal law should be preserved. Creating a Timeline for EPA Action: The bill, as introduced, suffers from a lack of express deadlines by which EPA must complete the work of prioritizing chemicals and assessing their safety. Timetables for action, along with requirements specifying minimum numbers of safety assessments and determinations to be carried out in a given time, must be added.
  • Prioritizing Chemicals Appropriately: Little or no information does not indicate little or no hazard. Therefore the bill should be amended to require that EPA designate a substance as low priority only when adequate data exists to show a chemical's relative safety.

Recognizing that considerable room for additional clarification and strengthening of this bill exists beyond these key concerns, the Sierra Club looks forward to improvements in this legislative beginning.

Safe Chemicals Act of 2011 (Toxic Substances Control Act (TSCA) Reform Bill)

To amend the Toxic Substances Control Act to ensure that risks from chemicals are adequately understood and managed, and for other purposes, Lautenberg's "Safe Chemicals Act of 2011" would require safety testing of all industrial chemicals, and puts the burden on industry to prove that chemicals are safe in order to get on or stay on the market. Under current policy, the Environmental Protection Agency (EPA) can only call for safety testing after evidence surfaces demonstrating a chemical is dangerous. As a result, EPA has been able to require testing for just 200 of the more than 80,000 chemicals currently registered in the United States, and has been able to ban only five dangerous substances. The new legislation will give EPA more power to regulate the use of dangerous chemicals and require manufacturers to submit information proving the safety of every chemical in production and any new chemical seeking to enter the market.
·Summary (2 pages)
·Full text (182 pages)
·Video: Lautenberg Introduces "Safe Chemicals Act of 2011" (3 minutes)


The Endocrine-Disrupting Chemicals Exposure Elimination Act of 2011
This targeted research and evaluation program on suspected endocrine-disrupting chemicals would establish greater scientific certainty with respect to the linkage of often unregulated chemicals with endocrine system effects. Credible linkages would make it possible for them to be regulated under the Safe Drinking Water Act, the Clean Water Act, and the Clean Air Act, and new legislation such as the Safe Chemicals Act of 2011, the Endocrine Disruptor Screening Enhancement Act of 2010. It would also promote voluntary actions to reduce exposure to these harmful chemicals through market forces.
·Full text (18 pages)

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