September 28th
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The National Center for Health Research (NCHR) appreciates the opportunity to express our views on the Environmental Protection Agency’s (EPA) Draft Revision for Toxic Substances Control Act (TSCA) Risk Determination on Carbon Tetrachloride.
NCHR is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which prevention strategies and treatments are most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
NCHR strongly supports the EPA’s reconsideration of risk evaluations of carbon tetrachloride using a whole chemical approach. A whole chemical approach rather than a “conditions of usage” approach is more useful for determining unreasonable risk of injury from the chemical substances defined in the TSCA. The whole chemical approach will do a better job of establishing safe baselines and measures for the health and wellness of children and adults. This is particularly important regarding carbon tetrachloride, which under the previous method, determined reasonable risk in only two of the 15 conditions of use: distribution in commerce and reactive ion etching, both of which have been shown to pollute groundwater.[1]
We also strongly endorse the EPA’s decision to exclude the assumption of Personal Protective Equipment (PPE) usage when considering the unreasonable risk of carbon tetrachloride. By not assuming everyone uses PPE or uses it correctly, EPA can better ensure the safety of anyone exposed to carbon tetrachloride, and especially those exposed at work. Moreover, this decision will enhance health equity, since most facemasks and respiratory protective equipment are based on male, Caucasian facial features. [2,3] As a result, PPE may be less effective for women and non-white individuals. For example, a survey in the UK reported that 57% of the women stated that their PPE sometimes or significantly hampered their ability to work. [3]
In response to the EPA’s “Risk Evaluation Scoping Efforts Under TSCA for Ten Chemical Substances” [EPA–HQ–OPPT–2017–0002; FRL–9959–36] in 2017, our research center recommended “a comprehensive evaluation of uses” as well as consideration of the fact that some users may “not follow every safety precaution” when determining the unreasonable risk of the ten chemical substances. We appreciate that the current draft reflects those concerns and urges EPA to continue its efforts to improve the implementation of TSCA.
If you have any questions about our statement, we can be reached at info@center4research.org or at (202) 223-4000.
References:
- P Jiang et al 2017 IOP Conf. Ser.: Earth Environ. Sci. 82 012058
- J. W. R. Verberne, P. R. Worsley & D. L. Bader (2021) A 3D registration methodology to evaluate the goodness of fit at the individual-respiratory mask interface, Computer Methods in Biomechanics and Biomedical Engineering, 24:7, 728-739, DOI: 10.1080/10255842.2020.1849156
3.Trade Unions Congress. (2017). Personal protective equipment and women. London, UK.