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This post is a continuation of the series on TSCA and exposure assessment. Today�s topic is manufacturing and processing notices, including the requirement to protect against unreasonable risks. 15 CFR 53 Part 2604 discusses the general requirements for manufacturers and processors. In short, no person can manufacture a new chemical substance or manufacture a chemical substance for significant new use (as determined by the Administrator of the U.S. Environmental Protection Agency) without: Submitting an intention to manufacture or process the substance at least 90 days prior Waiting for the Administrator to make a review and determination of the substance Taking the actions required by the determination How does the Administrator determine if use of a chemical substance is a significant new use? First, the Administrator receives the notification from the manufacturer or processor. Second, the Administrator considers all relevant factors. What are the � relevant factors � for considera...

Continuing the series on TSCA and exposure assessment, today�s blog post is about the testing requirements for chemical substances in TSCA. 15 CFR 53 Part 2603(a) explains the testing requirements. This is best explained in a graphic (made by me and you're welcome to use it): Flowchart of TSCA Testing Requirements If a chemical fits the requirements explained in the image above, the Administrator (of the U.S. Environmental Protection Agency) will call for testing to be conducted on the substance or mixture. The testing must show whether the manufacture, distribution, processing, use, or disposal (or any combination of these activities) DOES or DOES NOT present an unreasonable risk of injury to health or the environment. The Administrator can also require the development of new information relating to a chemical substance or mixture � this is at the discretion of the Administrator, to establish the priority (either high-priority or low-priority) of the substance or mixture. This pr...

I found this video about understanding the difference between hazard and risk, and the process of risk assessment. It covers the basics and looks to be a decent resource to use in my classroom. 

While I was revising my SHM 477: Environmental Management course for the next academic year, I found myself overwhelmed by the volume of information about the changes to the Toxic Substances Control Act (TSCA) . There is a slew of information out there, most of it by the U.S. Environmental Protection Agency, but it is strangely structured and not all of it is user-friendly. Hence, this post and the series that will follow on TSCA. The revised regulations for Toxic Substances Control are found in Chapter 53 of Title 15, and the text of the new requirements is in Subchapter I, �Control of Toxic Substances.�   15 CFR 53 Part 2601(a) explains the focus of Subchapter I, �Control of Toxic Substances,� to be on chemical substances and mixtures that are manufactured, processed, distributed in commerce, used, or disposed, and which �may present an unreasonable risk of injury to health or the environment.� � Unreasonable � is the key word here, and it is not defined. All the regulation says ...