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Proposed changes by the Environmental Protection Agency to right-size the Toxic Substances Control Act’s “framework rule” will help restore common sense to the evaluation of existing chemicals for unreasonable risk, the NAM and nine allied associations said recently.

What’s going on: In September, the EPA announced draft amendments to the framework used by the agency to determine if existing chemical uses present unreasonable risk to human health or the environment.  

• The proposed revisions would remove NAM-opposed changes made under the previous administration in 2024—ones that “produced sprawling, thousand-page analyses that are unnecessarily confusing, unrealistic and detached from how chemicals are actually used,” according to the NAM.

Why it’s important: “A well-designed framework rule will strengthen public confidence, promote interagency coordination and provide manufacturers with the certainty needed to innovate and invest in the United States,” NAM Vice President of Domestic Policy Chris Phalen said.

• The EPA’s stated aim in proposing targeted changes to the 2024 amendments is to “ensure that the procedural framework rule does not impede the timely completion of risk evaluations or impair the effective and efficient protection of health and the environment.”

What should be done: The NAM supports the EPA’s moves on the framework rule. For optimal results, manufacturers urged the agency to take several actions. These include:

• Exercising thoughtfulness in using “reasonable discretion” in the scoping of risk evaluations, “to avoid unintentional forfeiture of the important preemption protections established under TSCA Section 18”;
• Making each component of every risk evaluation “fit for purpose”; and
• Using “clear, practical mechanisms” to document coordination with other federal agencies during the scoping and risk evaluation of each chemical review.

The final say: “Manufacturers support the agency’s goal of evaluating existing chemicals and issuing safety determinations that are grounded in risk—considering both exposure and hazard—through a transparent process that utilizes sound science,” Phalen said.