Lynn L. Bergeson, Kelly N. Garson, and Lara A. Hall, “Testing, Testing,” Environmental Forum, March/April 2025.

A key force propelling reform of the Toxic Substances Control Act through Congress in 2016 was a bipartisan belief, shared by the business and environmental communities alike, that the Environmental Protection Agency needs more information to do its job of protecting the American public from adverse effects caused by chemical exposures. After all, it has been domestic policy under TSCA for almost a half century that “adequate information should be developed . . . and that the development of such information should be the responsibility of those who manufacture and those who process such chemicals.” Most stakeholders would agree more chemical information is better than less. So why is generating chemical data so difficult and fraught with legal, regulatory, and commercial challenges? This article provides the answers.