Policy Masthead



Toxic Substances Control Act (TSCA)

Modernizing the Federal Toxic Substances Control Act (TSCA) will go a long way toward enhancing the public’s confidence in responsible management and regulation of chemicals. A key ACI goal in TSCA modernization is to ensure members’ ability to innovate and formulate. ACI is committed to targeted risk-management measures that focus priorities and are practical, timely, transparent and responsive to the needs of consumers and other stakeholders. The resulting program should encourage innovation and acknowledge the benefits our products provide to enhance health and the quality of life.

Over the years ACI has also been active in supporting effort to improve the efficiency and effectiveness of EPA products under its current TSCA authority through dialogue and submission of comments.

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March 20, 2017 - ACI comments to Environmental Protection Agency, Procedures for Prioritization of Chemicals for Risk Evaluation Under TSCA:

ACI told the Agency that we support "EPA’s efforts to articulate and establish a process for prioritizing substances for review under the amended TSCA. ACI encourages EPA to a) make clear the standards it will apply in the pre-prioritization process, b) use a flexible approach when interpreting how it will make the Low-Priority designation, and c) arrive at final prioritization procedures under the proposed "framework" rules that will enable the Agency to adopt a bold vision and approach by which EPA will make determinations to identify large numbers of Low-Priority substances swiftly using the information and data currently available on such substances."

March 20, 2017 - ACI comments to Environmental Protection Agency, Procedures for Chemical Risk Evaluation Under the Amended Toxic Substances Control Act:

In written comments, ACI encourages "EPA to consider the two operations, Prioritization and Risk Evaluation, to be closely linked and believes the Agency should use the processes as a means to swiftly sort out large groupings of chemicals and chemical-use combinations that do not require the most immediate attention, and then to concentrate its Risk Evaluation resources and efforts on those substances and conditions of use that are the most likely to present the greatest risk on the basis of factors considered and identified during the prioritization process. This requires that the Agency must be willing to use a flexible approach that will enable EPA to sort large groups of substances in a manner that will recognize and temporarily remove from detailed consideration (or information gathering efforts) lower priority substances and conditions of use combinations.

"Likewise, the closer review of high priority substances requires the Agency to effectively and narrowly define the scope of the Risk Evaluations it intends to undertake. This is the most productive way in which EPA will be able to focus its limited resources on those chemical and use combinations of greatest concern. Doing so will permit EPA to undertake and complete Risk Evaluations more readily and will not unnecessarily obligate the Agency to identify and immediately assess all foreseen uses of a substance and all potential opportunities for exposures to a substance at the same time. ACI encourages EPA to avoid overburdening itself in favor of undertaking and completing more targeted Risk Evaluations in a credible manner that will rely on the information available to EPA and reflect the use of sound science while applying a weight of the evidence approach."

March 14, 2017 - ACI comments to Environmental Protection Agency, TSCA Inventory Notification Requirements

In written comments to EPA on its implementation of the TSCA Inventory Reset, ACI said in order to "minimize the reporting and processing burden on EPA and on the regulated community, and to minimize the opportunity for omissions, ACI recommends that EPA establish a reporting system in which the interim non-confidential active substances list is publicly updated on an on-going real-time basis throughout the reporting periods. This would reduce the number of duplicative reports, thus reducing unnecessary costs and effort. If real-time updates are not feasible, EPA should consider specifying periodic, either weekly or biweekly, updates to reduce burdens on both manufacturers and the Agency."

March 6, 2017 - ACI Urges EPA to Focus on Intentional Use of Ingredients

June 22, 2016 - ACI Statement: Chemical Safety Bill Signed Into Law

June 8, 2016 - ACI Statement: U.S. Senate Passage of Chemical Safety Legislation

May 25, 2016 - ACI Statement: U.S. House Passage of Chemical Safety Legislation

May 19, 2016 - ACI Statement: Bipartisan Agreement to Modernize TSCA