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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