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August 24, 2022

B&C Quoted by Chemical Watch in Article “US EPA to consider all exposures in premarket chemical reviews”

Bergeson & Campbell, P.C.

On August 23, 2022, Chemical Watch quoted the Bergeson & Campbell, P.C. (B&C®) memoradum “EPA Will Discontinue Use of Exposure Modeling Thresholds When Assessing Health and Environmental Risks of New Chemicals,” regarding the U.S. Environmental Protection Agency’s (EPA) plan to discontinue the use of exposure modeling thresholds when assessing the health and environmental risks of new chemicals under the Toxic Substances Control Act (TSCA) New Chemicals Program.

Law firm Bergeson & Campbell said in an online commentary that it “disagrees that unilaterally scuttling this policy is scientifically justified or that it will add minimally to EPA’s workload”. Actually, the firm said, “having to assess otherwise negligible exposures means that EPA will have to calculate vanishingly small exposures by all possible routes and calculate risks for each”.

It is hard to see why the agency’s Office of Pollution Prevention and Toxics (OPPT) would not just alter the thresholds instead, “if data support doing so”, according to Bergeson & Campbell. The firm noted that the Office of Pesticide Programs (OPP) and the Food and Drug Administration (FDA) have long relied on their own thresholds defining safe levels of exposure when scrutinising substances, including fragrances in antimicrobials and food contact substances.

The lack of scientific explanation and opportunity for consultation on the OPPT update fails to reflect scientific integrity and “undermines the public’s trust that EPA is committed to making transparent decisions that meet the scientific standards under TSCA”, the commentary said.

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