The Toxic Substances Control Act (TSCA), passed in 1976, regulated the introduction of new or already existing chemicals. While thought of as strict and cumbersome when enabled by EPA, it wouldn’t be considered so today. This column is about EPA’s new approach to managing hazards associated with introduction of new chemicals.

”NO-HAZARD” REGULATION OF HAZARDS
More about paperwork than restriction, the TSCA grandfathered most existing chemicals. Its work product was an inventory; chemicals that were listed in the TSCA inventory were referred to as “existing chemicals.” Chemicals not listed were (and are now) referred to “new chemicals.”

It did not separate chemicals into categories of “toxic” and “non-toxic.” However, the TSCA did specifically regulate polychlorinated biphenyl (PCB) products. It did not screen based on volume beyond a de minimus value. Manufacture or importation of chemicals that were not on the TSCA Inventory (or subject to one of many exemptions) were prohibited. Of the more than 83,000 chemicals included in the TSCA Inventory, many are no longer manufactured or imported.

A HARD RESET
On September 24, 2008, EPA announced its intent to “reset” the inventory to more accurately reflect the chemicals in commerce today. Here are the following major changes:

• Hazards of all chemicals will be independently evaluated.
• Chemicals used in the highest volumes will receive more scrutiny, with risk in use to have a determinant impact.

IT’S A CHAMP
EPA’s new Chemical Assessment and Management Program (ChAMP) will fulfill commitments made in 2007 with North American partners Canada and Mexico to share information about chemical hazards. Each country is sharing scientific information and approaches to chemical testing and risk management. (Why wouldn’t this have been done already?)

SIZE DOES MATTER
There are two categories under ChAMP. Chemicals produced (or imported) at more than 1,000,000 pounds per year are High Production Volume chemicals (HPVs). Moderate Production Volume (MPV) chemicals are those produced (or imported) between 25,000 pounds per year and that level. Chemicals no longer manufactured or imported will be deleted from the inventory.