David Fischer Quoted in Article on EPA ‘Tiered’ TSCA Data Rule

Keller and Heckman Counsel David Fischer was quoted in the Inside TSCA article, “Stakeholders See EPA’s ‘Tiered’ TSCA Data Rule Aiding Pre-Prioritization.” The article discusses how the EPA’s new TSCA reporting rule could return to a “pre-prioritization” process for gathering toxicity data and other information on chemicals before it formally designates them as “high-priority.” 

David mentioned the importance of building the TSCA evaluation system to “get data in plenty of time to analyze it” and to seek clarification on any open questions “even before prioritization." According to David, the tiered concept proposed by the EPA might be a poor fit for the TSCA program because the shifting data requirements could be difficult to administer and because it would result in a continual stream of new data on each chemical. 

Going forward, the EPA should focus “on front loading the system for risk evaluation itself, versus what you might need for prioritization,” David said. “EPA has to be very careful [over] which chemicals it picks.” 

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