Herb Estreicher Quoted in Inside TSCA Article on TSCA Cumulative Risk Drafts

Keller and Heckman Partner Herb Estreicher was quoted in the Inside TSCA article, “Groups Offer Competing Reactions To TSCA Cumulative Risk Drafts.” The article discusses the U.S. Environmental Protection Agency’s (EPA) recent draft documents on adding cumulative risk analyses to Toxic Substances Control Act (TSCA) evaluations of existing chemicals. Environmentalists and industry officials have differing views on the matter. Herb commented that he is “glad to see that EPA will await Agency-wide guidance and established methodologies before quantitatively evaluating non-chemical stressors (i.e., radiological, biological, and other physical stressors; lifestyle conditions; and socioeconomic stressors) when conducting risk evals under TSCA.”

Still, he added that cumulative risk analysis and the “whole chemical” approach “will pose significant challenges for industry. Even with a delay in the consideration of non-chemical stressors, many of the major uses of the priority chemicals evaluated under TSCA Section 6 are likely to have a hard time emerging from a CRA without an unreasonable risk finding which would then apply to the chemical as a whole.”

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