Environmental Working Group advocates establishing a health standard, and requiring that chemicals meet this standard before they are allowed on the market. The goal is to ensure that chemicals are safe for infants and children or other vulnerable populations before they are placed in commerce, removing the worst chemicals from commerce quickly, efficiently and scientifically. This health standard would include a number of provisions:
Chemicals are prioritized for regulation based on their presence in people and their toxicity.
All data is public and accessible, ensuring vigorous oversight and the ability to promote safer alternatives and green chemistry.
Data requirements, including biomonitoring, a strong minimum toxicity data set, authority to require additional information, removal of confidential business information (CBI) obstacles, and use data, are key to determining the exposure levels and pathways and the risk to human health and the environment.
The determination of product safety is already based on scientific risk assessment that considers both toxicity and exposure. Toxicity data alone is insufficient to determine whether a product is safe. Moreover, it is critical that the data be reliable. All data, from whatever source, should be considered and used according to internationally recognized scientific principles. The approach and procedures outlined in the OECD's Manual for Investigating HPV chemicals are internationally accepted and include a well developed method originally described by Klimisch to evaluate and ensure the quality of existing data by considering the adequacy, reliability and relevance of the available information. Any database used for regulatory purposes must utilize such sound criteria and approaches to ensure the quality of evaluations.
As there are already efforts being taken by other regulatory authorities to address priority chemicals, we encourage California not to establish redundant programs. The state should work in collaboration with those other jurisdictions on a global basis to establish chemical management policies and procedures that are consistent and effective.
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Environmental Working Group advocates establishing a health standard, and requiring that chemicals meet this standard before they are allowed on the market. The goal is to ensure that chemicals are safe for infants and children or other vulnerable populations before they are placed in commerce, removing the worst chemicals from commerce quickly, efficiently and scientifically. This health standard would include a number of provisions:
Chemicals are prioritized for regulation based on their presence in people and their toxicity.
All data is public and accessible, ensuring vigorous oversight and the ability to promote safer alternatives and green chemistry.
Data requirements, including biomonitoring, a strong minimum toxicity data set, authority to require additional information, removal of confidential business information (CBI) obstacles, and use data, are key to determining the exposure levels and pathways and the risk to human health and the environment.
Animal testing alternatives are promoted.
The determination of product safety is already based on scientific risk assessment that considers both toxicity and exposure. Toxicity data alone is insufficient to determine whether a product is safe. Moreover, it is critical that the data be reliable. All data, from whatever source, should be considered and used according to internationally recognized scientific principles. The approach and procedures outlined in the OECD's Manual for Investigating HPV chemicals are internationally accepted and include a well developed method originally described by Klimisch to evaluate and ensure the quality of existing data by considering the adequacy, reliability and relevance of the available information. Any database used for regulatory purposes must utilize such sound criteria and approaches to ensure the quality of evaluations.
As there are already efforts being taken by other regulatory authorities to address priority chemicals, we encourage California not to establish redundant programs. The state should work in collaboration with those other jurisdictions on a global basis to establish chemical management policies and procedures that are consistent and effective.