ASDWA TSCA Comments and Next Week’s Webinar
ASDWA submitted its fourth set of comments on the EPA Toxic Substances Control Act (TSCA) Significant New Use Rules (SNURs) this week and will hold its second TSCA webinar in its three-part series next week.
On August 18, ASDWA submitted comments on the EPA TSCA SNUR for Significant New Uses of Certain Chemical Substances (20-7.B). In each of our comment letters, ASDWA has continued to urge EPA to use TSCA authorities as part of a holistic approach to ensure complete consideration of a chemical’s lifecycle in the environment, and preventing them from impacting drinking water sources and human health. This includes recommending closer coordination between EPA’s Office of Pollution Prevention and Toxics (OPPT) and the Office of Ground Water and Drinking Water (OGWDW) to consider additional data and information on analogous chemicals and inform decision-making processes.
These comments highlight particular concern for two of the chemicals in this SNUR because of their potential impacts to drinking water and human health from releases to surface water; the use and disposal of these chemicals where they can rapidly migrate into ground water and where they are difficult to remove with wastewater treatment. ASDWA’s recommends that EPA undertake a deliberative process…to assess and restrict the release of these chemicals into surface waters and in this regard is pleased to see that EPA is now “proposing to designate these reasonably foreseen conditions of use and other circumstances of use as significant new uses…(that) cannot occur without…a separate, subsequent EPA review and determination process associated with a Significant New Use Notification (SNUN).” Requiring SNUNs will ensure that locations of chemical releases will be recorded, even at levels that EPA has deemed to be protective, to identify responsible parties in the event of future contamination. Read ASDWA’s TSCA SNUR comments here.
August 26th ASDWA Webinar: TSCA and the Environment
Next Wednesday, August 26th from 1:00 – 2:30 pm (eastern time), ASDWA will hold its second webinar in the TSCA series featuring speakers from the Environmental Defense Fund and Earthjustice who will highlight the key links between TSCA and the environmental health, including programs and provisions that relate to drinking water issues. The speakers will also cover problems arising from EPA’s current implementation of TSCA and ideas for improving TSCA implementation to protect public health and strengthen environmental protection. Register for the webinar here. To view the recording of the first webinar with EPA, visit ASDWA’s webinar recordings page.
