Sunday, October 6, 2013

Controlling Chemicals in Commerce

Open email to Sen. Vitter (LA):

Dear Sen.Vitter,
    Chemical and Engineering News has reported that you, in cooperation with Sen. Lautenberg (NJ), have proposed Senate Bill 1009 to update the Toxic
Substances Control Act. The essence of the bill is to strengthen EPA's authority to ban a substances outright.
     Daniel Rosenberg of the National Resources Defense Council, a private organization, later registered several objections to your bill as follows:
It does not set deadlines or minimum requirements for prioritizing, assessing or making decisions on whether to regulate chemicals. Without them, likely nothing will happen.
It requires the Environmental Protection Agency to develop multiple overlapping procedures and criteria that will just tie the agency in knots and delay assessing chemicals.
It broadens state pre-emption so no action would be taken for years on “high priority” chemicals.
It doesn’t require EPA to protect vulnerable populations such as women, children and workers.
    I have no objection to your consideration of Daniel Rosenberg's suggestions, but I am much more interested in a separate point, which I consider extremely significant. That is, we have had experience with the EPA abusing arbitrarily any controls which have been delegated to them. I strongly suggest that as this bill is modified, it has a requirement that the EPA must revert back to a congressional committee for approval to ban a substance outright or to impose such limitations as to effectively create a ban.

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