EDF Blog Item States Country-Specific Exposure, Use Patterns, and Regulatory Requirements Matter More Than Chemical’s Approval Status in Other Countries

The Environmental Defense Fund (EDF) posted a blog item on August 27, 2026, entitled “American Chemical Safety Decisions Should Be Based on American Conditions of Use.” As we reported in our January 27, 2026, and March 6, 2026, memoranda, the House and Senate have each held hearings on discussion drafts of legislation that would amend the Toxic Substances Control Act (TSCA). EDF’s blog item explores why the Organisation for Economic Co-operation and Development’s (OECD) experience, policy, and modern risk assessment show that country-specific exposure, use patterns, and regulatory requirements are more important when evaluating a new chemical than approval status in other countries. EDF notes that the risk posed by a chemical depends on how the chemical is used, who is exposed, the magnitude and duration of exposure, and the protections in place to reduce harm. Because different countries may have different uses, exposure patterns, worker protections, and regulatory requirements, “it’s essential for [the U.S. Environmental Protection Agency (EPA)] to take into account how it will be produced and used in the United States prior to approval rather than relying on another country’s approval.” An OECD New Chemicals Task Force “identified fundamental challenges to one country automatically adopting another country’s risk-based new chemical decision.” According to EDF, “[i]n the end, the OECD walked away from the idea of the mutual acceptance of new chemical risk-based regulatory decisions. The concept may sound efficient in theory, but OECD participants concluded that new chemical risk-based decisions are too dependent on country-specific conditions to be automatically adopted by another jurisdiction.”