EPA's Control of Toxic Substances

As an add-on to my recent essay on revision of the Toxic Chemicals law, Chemical and Engineering News has come up with additional information on the EPA in its November 3 issue.
The EPA has added 23 chemicals to its list of chemicals for further scrutiny and potential control. It also removed 16 chemicals from the list, including 13 that the agency claims are no longer sold in the US. The changes have been made to reflect new data that industry submitted to the EPA concerning chemical releases and potential exposures. This marks the first time the agency has updated its list of chemicals since 2012. The list now contains 90 substances or groups of compounds that may cause reproductive, developmental or neurotoxic effects, are carcinogenic, or are in children's products.
The American Chemistry Council has objected to the new inclusion of bisphenol A and the group of phthalate chemicals on the basis that these substances have already been reviewed by other regulatory programs. Notice that the EPA has not banned these substances from sale; merely that the substances are being assessed for possible regulation. These products are important sales to the chemical industry, but should be banned if the EPA investigation shows any possible significant danger to public health. Let's hope that the EPA analysis will not take forever. If the substances are already doing damage in the society, the sooner we can remove them from the environment the quicker we will be able to show public health improvement.
With respect to chemicals stricken from the list as no longer in commerce, this is based upon EPA's limit of investigation involving production of 25,000 pounds or more at each production site per year. This seems unreasonable to me, because it doesn't allow for variations in toxicity for individual chemicals. For example, take the case of Tabun, which was developed as a pesticide in Germany in the 1930s. One gram of Tabun applied to the skin of a human body is a lethal dose. If we go strictly by the EPA investigation rules, Tabun could be produced at 10 different sites in quantities of 22,000 pounds per year, for a total of 220,000 pounds (100,000 kg) per year, and escape the EPA's investigation limit. At the lethal dosage of 1 g per person, that quantity could kill 100 million people.
I call on Sen. Imhofe, the new Chairman of the Senate Environment & Public Works Committee, to work with the EPA  in developing more practical procedures for determining what chemicals should be allowable for use and exposure to the public through commercial products.