March 23, 2017
Gradient and the Humane Society of the United States Collaborate to Provide Comments on the Implementation of Provisions under TSCA to the US EPA
Gradient is pleased to be working alongside the Humane Society of the United States (HSUS) to provide written comments to the US Environmental Protection Agency (US EPA) on the implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, also known as “the TSCA reform.” Based on a shared commitment to the protection of human health and the environment, Gradient and HSUS submitted comments that promote transparent prioritization processes and innovative toxicology and risk assessment strategies that will both improve chemical safety assessment as well as minimize the use of animal testing in such assessments. (Links to comments below)
Our comments emphasized the need for further clarity on the chemical prioritization and risk evaluation processes, as well as promote the use of non-animal testing alternatives as part of information gathering for data gaps. Specifically, we recommended that US EPA provide more transparency on “Pre Prioritization”, including publicizing the identity of chemicals being considered in the “Pre Prioritization” process; clarify the role of existing assessments such as those from the Integrated Risk Information System (IRIS); address how data gaps in the prioritization process will be handled; and dedicate significantly more resources for low-priority designations. On Risk Evaluation, we recommended that US EPA further clarify how exposures and risks will be evaluated across the full life cycle of the substance and set out processes for interpretation and implementation of such key terms as “sufficiency of information,” “best available science,” “weight-of-evidence,” and “unreasonable risk.”
We anticipate that these comments will aid US EPA in meeting the TSCA reform’s objectives to improve chemical safety and advance innovations in toxicological analysis that are more time- and cost-effective than animal studies.
Link to Gradient and HSUS comments: Procedures for Prioritization of Chemicals for Risk Evaluation and Procedures for Chemical Risk Evaluation.
Link to more information from HSUS on Animals in Laboratories.
Link to more information from HSUS on The Human Toxicology Project Consortium.