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Prevent Harmful Chemical Exposures
Discussion
 

Chemical Policy Reform 

CLOSED DISCUSSION

What chemical policy reforms would provide the best opportunities for reducing public health impacts of harmful chemical exposures?

Draft Action Agenda Contents and Introduction
Draft Action Agenda Chapter 1

Welcome 22 Replies New
Facilitator Gail Bingham
1/5/11 05:23 AM
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Welcome to the National Conversation on Public Health and Chemical Exposures’ second web dialogue. Our focus is on Action. With 400 participants from all across the country, I anticipate a great conversation! Thank you to those of you who participated in the first web dialogue for coming back. Greetings to those of you who are members of work groups or the Leadership Council and a warm welcome to people joining for the first time.

Our goal with this dialogue is to focus on the recommendations for action that have emerged from more than a year of work by partners in public health around the country and expert work groups, which were then synthesized by the Leadership Council into the draft Action Agenda we have today. Today and tomorrow, we invite you to engage in a dialogue about which recommendations you think will have the greatest positive impact, which you have concerns about and why, how you would strengthen these recommendations and what is missing. Your comments will be summarized and shared with the Leadership Council for consideration as they revise the draft Action Agenda in February and March.

In this topic – Prevent Harmful Exposures – we ask you to focus on the recommendations in chapter one of the draft Action Agenda. You can find it by clicking on the Library tab or the link at the top of this page. It’s worth reading and not that long! This discussion area is on Chemical Policy Reform.

You can also share your ideas about other chapters both in the two additional topics that also open today and in two more topics tomorrow. Please click the agenda tab for information about these topics.

We are very fortunate to have several people who are actively involved in the National Conversation serving as panelists to answer questions and engage in the conversation with you. Please take a minute to click their names to see their faces and learn more about them.

You can start in now with an idea about the discussion questions in the box above or a specific recommendation for action in chapter one by clicking “Introduce a New Idea” in the upper right corner of the box above. Your submission will create a new discussion thread. To respond to someone else’s message, click "Reply" in the bottom right corner of that message.

I am excited to read what you have to say! Gail
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ricky choy
1/5/11 05:07 PM
[jump to parent] in reply to Gail B.
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Chemical exposure
How can we minimize chemical exposure especially in a hospital setting wherein health authorities endorses the use of toxic chemicals like glutaraldehyde,peracetic acid, formalin or even the improper use of bleach as an all around disinfectant?
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Suzie Campbell
1/5/11 08:34 AM
[jump to parent] in reply to Gail B.
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exposures
Are we concerned with individual, group or community exposures? All three?
I am interested in exposures occuring or related to public bathing places (pools, spas, waterparks, fountains, etc.)
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Active Panelist Julie Fishman
1/5/11 08:49 AM
[jump to parent] in reply to Suzie C.
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Healthy Recreational Water
We are concerned with all three, but generally focus more on group/population health. Please elaborate on your concerns regarding public bathing places. You likely are aware of this already, but attached is the URL for the CDC website on recreational water.
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robert krieger
1/5/11 08:26 AM
[jump to parent] in reply to Gail B.
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Prevent Harmful Exposures
Confidence in the process is lost when exposures are not distinguished from "harmful chemical exposures." The methods that are used to identify the inherent hazards of chemicals in biological systems must also be used to discern no effect levels of exposure. Well established chemicals like ethanol, caffeine, and common medications are better place to start the conversation than "harmful [environmental] exposures" that occur at miniscule, but measurable, levels without biological consequence.

Preventing Harmful Exposures will occur if there is a greater commitment to improve our capability to discern adverse effects.
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An Ounce of Prevention
The bottom line to this is accountability.

Many of the "tolerable levels of exposure" to a (singular) toxic chemical have been fraudulently produced for decades.

But it is well documented in the book "Toxic Deception that they have known this since the 1970's. In the 1950's, 1960's and 1970's, Industrial Bio-Test Laboratories (IBT) performed about 35-40% of all U.S. Toxicology testing. Of the 867 audits of IBT performed by the FDA under the 1962 law, 618 were found to be invalid because of numerous discrepancies between the study conduct and data. FDA flexed its muscles and found four IBT managers guilty of fraud." Yet the EPA has still been accepting these "studies" that are financed by industry, with out any real review !!!
http://www.westgard.com/guest16....

Test fraud again made headlines in 1994, when Craven Laboratories was fined over 15 million dollars.

Examples:
Fifty Years of Legislation, by CAROLINE COX
http://www.getipm.com/government...

The solution for this is "criminal
accountability" and will probably require
legislation to enact laws for criminal
accountability of corporate officials and
their "Reckless Operation of a Corporation",
with mandatory jail terms, fines in sentencing.

Here is a web page that I have made, regarding
this, with reference material posted:>

American Roulette:
http://sites.google.com/site/tox...

Excerpts from the page :>

American Roulette:
Revolvers are for Russians. We use products, services and labor rights.

Example;
Think – state reckless homicide prosecutions for death on the job.


Only a few corporations have been charged and convicted of
negligent homicides of their workers (162).

The district attorney that convicted Jeffrey Dahmer also
convicted ten corporations of negligent homicide (162).

The reasons why this is so rarely done are investigated, here (work in progress).
http://sites.google.com/site/tox...


Please note this article titled;
Crime Without Conviction: The Rise of Deferred and Non Prosecution Agreements
By Russell Mokhiber Editor of Corporate Crime Reporter
December 28, 2005 and posted at
http://www.corporatecrimereporte...

-----

A rather long list of "reckless operation of corporations"
that have resulted in "Negligent Homicides" is documented
in a highly censored report titled:

Skeletons in the Courthouse:
Hazards to the Public Remain SecretApril 2002 by the Coalition for Consumer Rights Download PDF



Regards,

The Toxic Reverend
http://twitter.com/toxicreverend
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Elizabeth O'Nan
1/5/11 09:38 PM
[jump to parent] in reply to robert k.
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Prevent Harmful Exposures
Adverse affects today are most often denied or attributed to anything other than chemicals this of course greatly affects our ability to discern their existence. This is due mainly to the fact that our physicians continue to be "maleducated" in diagnosing and treating chemical injuries and disabilities. Also, chemically injured and disabled citizens are not able to find medical care for their many ongoing injuries and degenerative disorders unless they are occupationally related or require urgent care. Our government continues to deny the existence of Toxicant Induced Loss of Tolerance or Multiple Chemical Sensitivity despite the exponential growth of these patients and ignores the needs and causes of this suffering. Until we admit what has been done by toxic chemical exposures, we shall continue to ignore the need to stop the poisoning or discern adverse affects.

One problem that could be addressed are the RCRA laws that allow hazardous waste to be hidden (recycled) within other chemicals. There is too little supervision of this process and in pesticides particularly I have found that previously banned, recycled hazardous waste, and radioactive NORM waste as well as other forms of radioactive recycled products such as xylene may be included in pesticide products. The recycling "greenwashing" should be prohibited as it falsely gives the appearance that we are producing less hazardous waste when we are merely shifting it about often, synergistically speaking, in a far more toxic form. At the very least when toxic materials are recycled into other products they should be clearly labeled as containing "Recycled Hazardous Waste" in their ingredients.

In another related area the EPA scientists need to be educated regarding the clear warnings from Rachel Carson regarding mixing pesticides with radiation. Russia has shown in several studies that cell death is greatly increased in these mixtures, yet there seem to be no experts in exploring these deadly mixes. There are pesticide experts and radiation experts, but oddly no one seems interested in what happens when we mix the two, much less regulation of this problem. My advice would be to keep radiation out of pesticides and closely examine this issue.
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Bill Osmunson DDS, MPH
1/5/11 09:23 AM
[jump to parent] in reply to robert k.
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Prevent Harmful Exosures
Robert, your excellent approach to preventing harmful exposures must start with the CDC no longer promoting unapproved drugs.

Drugs are toxic in the wrong dosage or for the wrong people. Unless the drug is FDA CDER approved, the CDC has no business pushing the illegal drug, such as fluoridated water.

The first step for preventing harmful exposure is for the CDC to obey the law.
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Active Panelist Lin Kaatz Chary
1/5/11 09:01 AM
[jump to parent] in reply to robert k.
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Let's be proactive rather than reactive
Robert, while I appreciate your concerns about what you characterize as well-established chemicals, I'd like to look more closely at what we define as "well-established." Who sets the criteria and based on what? If exposure is the primary metric, we start out at a disadvantage and then have to struggle forward reacting to exposures which are often beyond our ability to control, and, as history has shown in numerous cases, often extremely difficult to predict, which therefore also makes it difficult to predict or address risk as well. We have seen the result of this in our current regulatory structure - a tremendous financial burden on industry with regard to testing, not to mention liability and remediation, and of course, the health care costs which are externalized. The approach we have taken in our recommendations is to recognize that exposure is not a process consistent with the public health imperative of primary prevention, which is fundamentally proactive and much more beneficial economically (among its many other benefits) in the end.
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Joseph Hughes
1/5/11 06:19 AM
[jump to parent] in reply to Gail B.
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Chemical reform
What is politically realistic to propose for TSCA reform given the current environment?
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Active Panelist Timothy Malloy
1/5/11 09:09 AM
[jump to parent] in reply to Joseph H.
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Chemical Reform
That is an excellent question. Prior to the mid-term elections, there seemed to be at least some consensus that reform or "modernization" was necessary. I am not optimistic that anything more than incremental tune-ups of TSCA are likely though (fixing at least some of the structural problems associated with testing and information collection, but even that would be helpful. Adoption of rsik-based standards similar to the Food Quality Protection Act are also possible, I think.
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James Cooper
1/5/11 09:28 AM
[jump to parent] in reply to Timothy M.
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FQPA
Tim - While FQPA standards may be appropriate for chemicals that are used on food products intended to be ingested, they are not a good model for industrial chemicals. Because of the wide variability in the uses of and potential exposures to industrial chemicals, a much more comprehensive approach is needed to define chemical safety. Therefore, I don't think the FQPA standards will have much traction.
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Active Panelist Gail Shibley
1/5/11 09:15 AM
[jump to parent] in reply to Timothy M.
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fqpa
tim, do you consider the food quality protection act a success? that is, would achieving such standards (just a bit later than fed law required) be a worthwhile policy goal?
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James Cooper
1/5/11 08:28 AM
[jump to parent] in reply to Joseph H.
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Chemical Policy Reform
The political environment has changed, which I think will result in a more balanced proposal. There are some who think that EPA should be allowed to "manage" whatever it wants whenever it wants. Giving EPA carte blanche authority is not the answer. Appropriate chemicals management should be based on the hazards of chemicals AND the potential to which people or the environment could be exposed to those chemicals. Chemicals management is a complex subject and creating policy in this area should be afforded an appropriate amount of time to create something that will work and not drive more manufacturing jobs overseas. Chemicals management must also protect American intellectual property. If a multi-stakeholder approach were used to develop a rational framework for chemicals management, it would maximize the chances for successful TSCA reform. Both political parties should strive to balance the need for pertinent chemical information and appropriate management of chemicals with the need for innovation, a strong manufacturing base and good-paying jobs.
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Active Panelist Gail Shibley
1/5/11 09:11 AM
[jump to parent] in reply to James C.
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reform q
james, where do you think the burden of proof should lie -- with the epa (or other govt. agency) to act, or with the party wanting to introduce/use a chemical or mixture?
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James Cooper
1/5/11 09:35 AM
[jump to parent] in reply to Gail S.
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Burden of Proof
Realistically, Gail, I think that industry will never have the authority to declare a chemical as safe. While industry has and will continue to provide safety-related information, people will continue to look to the government and liability laws to ensure chemical safety. The question becomes: What is sufficient information for EPA to decide whether or not a chemical is safe? If EPA focuses on the uses of chemicals, rather than just on the chemicals themselves, it would increase its effectiveness in managing the safety of those substances. EPA already uses a measurement called the Margin of Safety (aka Margin of Exposure) to make those decisions. I would not expect that to change much, even with TSCA modernization.
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Active Panelist Lin Kaatz Chary
1/5/11 09:55 AM
[jump to parent] in reply to James C.
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Burden of proof
Attempting to define whether or not a chemical is "safe" will, I think, lead us further into the bog, because at this point, any definition is highly value-laden. But placing the burden of proof on the designers, manufacturers and users of chemicals is a different question. Right now the onus is on the public to prove that there is harm. The question I have for James is whether you think that's appropriate or not? I think that a world without risk is as unrealistic as you do - but that's long way from saying we can't improve upon our current situation. In this process we have been trying to articulate recommendations for processes and approaches that will better protect the public from chemicals which are known to be inherently harmful, and to reorient our thinking in terms of the design, production, and use of new chemicals and processes so that our objective is the minimization, if not the elimination, of hazard wherever possible. We will always have to devote time, energy and resources to addressing risk and exposure, but the question is, whose job should that be? And can't we do a better job than we have been? Although we have focused on TSCA, it is our constellation of fragmented and risk-based regulatory instruments that needs to be changed. Shifting responsibility is one step; having a system driven by hazard reduction rather than risk reduction is the key.
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James Cooper
1/5/11 01:22 PM
[jump to parent] in reply to Lin K.
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Burden of Proof
I guess I'm not sure how "burden of proof" is defined in the conversation. Under REACH, registration submitters provide information and governments evaluate that information and make a decision on whether or not the chemical can be used safely. People seem to be saying that REACH shifts the burden of proof to industry; however, the main difference between REACH and how we approach chemicals management in the US is the amount of information submitted to the government for evaluation. Both governments still use traditional risk assessment approaches to evaluate the information and similar criteria for decision-making.
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Bill Osmunson DDS, MPH
1/5/11 01:06 PM
[jump to parent] in reply to Lin K.
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Burdon of Proof
Drugs are toxins prescribed for a specific person for a specific disease and with the intent of the patient.

The FDA CDER is a good model. The FDA could never regulate all drugs if they were the "policeman/inspector" of drugs. It would be an impossible task with huge resources. The burdon of drug approval is on the manufacturer.

The same process should be used for manufacturing and use of any toxic substance. Regulation of environmental toxins must be on the manufacturer to gain approval before introduction into the environment.

Manufacturers need to go to the EPA with a proposal rather than the EPA and public finding out about toxic spills, damage, after the fact.

AND government must be held accountable for promoting the use of toxic substances. The CDC should not be permitted to promote unapproved drugs such as fluoridation.
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James Cooper
1/5/11 01:26 PM
[jump to parent] in reply to Bill O.
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Burden of Proof
So, Bill, are you saying that a toxic industrial chemical that is used in a closed system to make another, different chemical, and is never seen by the general public, should be subject to the same type of risk management as drugs that are intended to be ingested?
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Bill Osmunson DDS, MPH
1/5/11 05:18 PM
[jump to parent] in reply to James C.
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Burdon of Proof
James, thank you for asking and I did not make myself clear and perhaps this concept is unworkable.

No, I do not think chemicals should be subject to the same type of risk management standards as drugs, but the process should be similar.

I do think the regulatory agencies for chemicals should operate like the FDA. In some ways they do at this time.

The manufacturer tells the FDA what it will make, how it will be made, the label of any claim, etc. The responsiblity for safety is on the manufacturer and the FDA reviews the manufacturer's application and approves the application if appropriate.

The same type of responsiblity should be on manufacturers using chemicals. The manufacturer of the chemical should be held responsible.

The burdon of safety should be on the manufacturer rather than the EPA.
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Inactive Panelist Brenda Afzal
1/5/11 07:01 AM
[jump to parent] in reply to Joseph H.
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Chemical Reform
The public health community is very concerned about chemical policy reform and I believe we are in agreement that we must work together for all reform that is needed and not just that which may be considered politically realistic. The community appreciates this as a health issue first.
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Active Panelist Patricia Beattie
1/5/11 06:23 AM
[jump to parent] in reply to Joseph H.
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Chemical reform
I think that it will be important for all voices to be heard in the dialogue for TSCA reform. The chemical industry is still supporting reform, so this should keep the effort alive.
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Primary prevention 25 Replies New
Active Panelist Elise Miller
1/5/11 06:43 AM
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In the draft intro of Chapter 1, primary, secondary and tertiary preventative practices are mentioned. I think it is important to clarify that the "new approach" referred at the bottom of page one, is really not new--it IS primary prevention. It is about instituting policies and regs that encourage primary prevention at all levels for all populations, and if necessary, responding rapidly and efficiently when vulnerable populations are not being protecting sufficiently (those responses would of course be considered secondary and tertiary). I think the intention here is to suggest that primary prevention needs to become the norm, rather than an afterthought.
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Jennifer McKinnis
1/5/11 09:04 AM
[jump to parent] in reply to Elise M.
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Education First
I like the draft recommendations and the concept of primary prevention... In order for it to work, the public officials are going to need massive re-education. There are a lot of in-gained biases and bigotries surrounding these issues. It is primarily due to ignorance. If the people who are supposed to protect you don't believe that your issue is real, they deny you the protection you need. I and thousands of people with toxic injuries, that I've communicated with, have been repeatedly denied our civil rights to life, liberty and full access and use of our property by the very people who are supposed to protect those rights...

I'd like to see that addressed in this conversation. If the people in office deny you assistance, due to their own bigotries or political agendas, it doesn't really matter what is written into the law. They are already violating the ADA.
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Active Panelist Timothy Malloy
1/5/11 09:15 AM
[jump to parent] in reply to Jennifer M.
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Chicken and the Egg Problem
I agree completely with your point Jennifer, although I do worry about the chicken and the egg problem. From an organizational and cognitive standpoint, people--including public officials--I think tend to learn things and internalize them when they have to as a matter of necessity. I believe that effective, meaningful implementation of primary prevention will require both re-education and enforceable mandates at the same time in a coordinated fashion.
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Jennifer McKinnis
1/5/11 01:23 PM
[jump to parent] in reply to Timothy M.
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Enforceable Mandates
Yes Timothy, you are right. Both education and enforceable mandates will need to be implemented. Enforceable mandates or regulations, laws and policy take longer...

For people like me, every day is a struggle to overcome the barriers imposed on us by the toxic poisoning that We've received. Every day can be life threatening. Most days are. For me, and the 140 millions like me, the faster we get people educated about these issues, the better.

In my experience 80% of the people will make gracious accommodation with even the minimum of education. They are good people. That 80% buys us a lot more space in our severely amputated lives. Let's not wait to begin educating, until any new enforceable mandates are in place. Technically there are already laws in place, they're just not being applied liberally as they were intended...

The ADA already states that no one, not public servant, nor person in private business, not even an individual can prevent access to a disabled individual, on the basis of their disability, to any public space or private business. It also liberally defines disability to even one burden of any kind...The toxically injured have multiple burdens, disabilities and barriers. Yet, we are still unrequited.
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Geri Aird
1/5/11 08:35 AM
[jump to parent] in reply to Elise M.
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Wingspread Statement on the Precautionary Principle
How can the Precautionary Principle be applied in developing regulations to protect people from chemicals and pollutants related to natural gas and oil production and storage.
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Barbara Warren
1/5/11 08:19 AM
[jump to parent] in reply to Elise M.
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Primary Prevention and the Private Sector
I fully support Elise's comments about primary prevention and the precautionary approach.

I have major concerns about three recommendations in Chapter 1 which recommend that Federal Agencies work with the private sector to develop scientific methods and address precaution. This conversation should be about increasing involvement of the public, and those working on public health or advancing the public interest. Recommendations 1.4, 1.7 and 1.8 should be amended to reflect increased involvement of these parties. The Private sector has too much influence already and with adverse outcomes.
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Active Panelist Gail Shibley
1/5/11 08:34 AM
[jump to parent] in reply to Barbara W.
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private sector
would your concern remain if these three recommendations called for larger involvement -- w/ public health professionals, academia, etc., and not only private sector?
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Barbara Warren
1/6/11 09:02 AM
[jump to parent] in reply to Gail S.
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private sector

I should have also clearly stated that organizations working in the public interest should be included as well as community representatives.
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Barbara Warren
1/5/11 09:42 AM
[jump to parent] in reply to Gail S.
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private sector
Any involvement of the private sector is tainted by their overwhelming political influence. However, I expected these recommendations to reflect the balance you suggest-- rather than to just turn science and public health over to the private sector.
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Active Panelist Gail Shibley
1/5/11 11:34 AM
[jump to parent] in reply to Barbara W.
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(re)building trust in government
thanks so much for your comments, barbara. apropos this issue, i would ask your perspective on recommendation 5.6 (page 55 of the draft) that, i think, also attempts to address the larger issue of building (or rebuilding?) trust in government and the products it produces. your thoughts are very valuable.
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Barbara Warren
1/6/11 09:10 AM
[jump to parent] in reply to Gail S.
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Building trust in Government
Sorry for the delay but I have found this process difficult-- following multiple threads, etc. while other competing demands are occurring.

Concerning Rec. 5.6, I think the ombudsman is overly constrained by the wording, " investigate allegations of scientific misconduct with regard to government studies." I think very few situations would actually be captured here. I recommend a broader scope for the ombudsman to oversee studies, communications and public involvement and to endeavor to represent the public interest. Poor study design, lack of adequate power due to sample size, asking the wrong questions would not necessarily constitute scientific misconduct. An ombudsman's job should be to improve trust in government.
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Amy Bates
1/5/11 08:19 AM
[jump to parent] in reply to Elise M.
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Primary Prevention
I agree with Elise, primary prevention needs to become the standard. I also agree that partnering with the local community is important; however the burden for prevention should not rest prediminantly upon the community, as many communities (particularly the under-represented) manifest chronic capacity challenges. When employing primary prevention, I would like to know how the precautionarly principle could be used to reduce risk.
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Active Panelist Patricia Beattie
1/5/11 06:56 AM
[jump to parent] in reply to Elise M.
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Primary Prrevention
Thanks, Elise. You are absolutely correct - primary prevention is the goal. Do you thoughts on what policies and regs need to be revised to achieve this goal?
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Active Panelist Elise Miller
1/5/11 09:55 AM
[jump to parent] in reply to Patricia B.
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Primary prevention - response
The most obvious is TSCA reform on the federal level as well as chemical policy reforms on the state level. Fortunately, there are many colleagues--researchers, health professionals, health-affected groups and advocates, who are working collaboratively to press for these reforms. The current political climate will make it more challenging nationally, but there are some stronger state-based opportunities this year.

However, in order to fundamentally shift from a mostly tertiary approach to a primary one, we need to look at cumulative stressors on health, and viable points of intervention involving a wide-range of sectors. Not infrequently the community level is the best place to test and model new ordinances which different sectors, including neighborhood groups, come together to develop. For example--Sandra Steingraber's town in update New York has passed an ordinance banning fracking; other towns in New Jersey and Minnesota are drafting ordinances regarding where certain industries might relocate or build new facilities so that communities, particularly low-income and minority communities, are protected. These are based on a precautionary approach--meaning that primary prevention is made the center of the decision-making structures.

In addition, our legal system currently does not have a mechanism to address cumulative impacts. That is another area that will need to be enhanced so that communities will have a legal reference for developing protective parameters.

What I am, of course, suggesting here is a more complex, systems approach to protecting health, that includes not only reducing toxins in the environment (which is obviously extremely important), but addressing socioeconomic inequities, nutrition, and other interacting factors that are beyond the scope of this particular conversation--yet ultimately need to be examined and integrated if we are to effectively protect and sustain human and ecological health.
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Arthur Lee
1/5/11 06:56 AM
[jump to parent] in reply to Elise M.
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Primary Prevention
I do believe that one of the overlooked aspects of primary prevention is a well informed local community. I have concerns that there have not been systematic engagement of neighborhood organizations. Some, of course, are not well organized. However, having neighbors organize around these issues with good leadership can help. Sometimes local policy makers themselves are not well informed. Active engaged neighbors and communities will help keep them aware.
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Active Panelist Pam Eliason
1/5/11 08:10 AM
[jump to parent] in reply to Arthur L.
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Toxics Use Reduction Institute: Community (URL)
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Engaging communities in primary prevention
You are absolutely correct that grass-roots efforts can lead to valuable gains, especially when partnered with the right technical support.

In Massachusetts the Toxics Use Reduction Institute (TURI) works directly with communities to promote significant reductions in the use of toxic chemicals. Typical projects include switching to safer cleaners and disinfectants by cleaning services and in schools and institutions, promoting the use of Integrated Pest Management, switching local businesses from carcinogenic solvent-based dry cleaning to highly effective and safe wet cleaning, and promotion of safer chemicals and working practices in nail salons (to mention only a few).

You can learn more about our approach at our TURI websites for the community, and for home made household cleaner recipes, see attached URLs.

You can contact Joy Onasch, or Community Program Manager, to learn more: 978-934-4343 or joy@turi.org
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Arthur Lee
1/5/11 12:01 PM
[jump to parent] in reply to Pam E.
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Engaging communities in primary prevention
Thanks. Will check the site as soon as I finish this acknowledgement.
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Jennifer McNew
1/5/11 08:02 AM
[jump to parent] in reply to Arthur L.
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Collaboration
I agree. I'd like to add that perhaps the closer emergency responders & community planning organizations work with private industries to have prevention/fast response plans in place, it could prevent a significant number of incidents and/or reduce the number of those affected.
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Shannon Cox
1/5/11 08:22 AM
[jump to parent] in reply to Jennifer M.
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The Front Lines
I agree with both Arthur and Jennifer. Southwest Center for Pediatric Environmental Health has begun an initiative to educate and inform our regional advisory committees in community planning such as government officials, emergency responders, healthcare administration, and schools in the area of exposures of children. We have had great success in educating these populations about potential exposure issues, new policy and funding opportunities. I have been amazed at the lack of knowledge in these areas among the groups and the lag in information dissemination. It is essential that education in a timely manner be a focus in reducing chemical exposures. In regard to recommendation 1.3, we need to ensure schools are included in any disaster planning initiatives and chemical exposure planning, since this is where children spend majority of their time. We are finding that many schools and disaster planning committees are lacking these collaborations.
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Active Panelist Patricia Beattie
1/5/11 07:37 AM
[jump to parent] in reply to Arthur L.
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Primary Prevention
Thanks, Arthur. What policies or regs could be changed to improve local involvement and engaged communities?
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Arthur Lee
1/5/11 08:34 AM
[jump to parent] in reply to Patricia B.
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Chemical Policy Reform
I completely missed your request. I am getting used to this way of communicating in semi-real time. especially since I'm going from topic to topic to see the other conversations. I know we can be more efficient in engaging community conversations with the powerful technologies we have at our disposal. Policy changes recognizing the potential uses of digital tools to engage communities in helping to craft policy would be good. Community engagement in zoning policy is underused and in too many cases manipulated by industries that may produce necessary but potentially toxic materials when using 19/20th century information sharing tools. Hearings are stacked with plain clothed industry reps looking like neighborhood folk when the neighborhood was only minimally informed. Communities, even in underserved areas have access to libraries with internet connections. Legally recognized neighborhood associations can be included in such policy as recipients of key information about current and potential chemical exposure.
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Active Panelist Lin Kaatz Chary
1/5/11 09:30 AM
[jump to parent] in reply to Arthur L.
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The CARE program
Hi Arthur. Thanks for raising this important issue. Are you familiar with the CARE program - Community Action for a Renewed Environment? This is an ATSDR program under which communities can apply for grants to do some of what you discuss above. The purpose of the CARE Partnership is to promote community involvement at the grass-roots level to identify and create action plans to address environmental problems in the community. In my community, we are entering the third year of our Partnership, and one of our goals is to see the group eventually be able to do exactly what you propose. We have also used the resources of the National Conversation on the local level and have had several meetings which piggyback the National Conversation with the CARE project. The CARE program is unfortunately severely underfunded, but I really encourage communities to look into this, because unlike many other programs, this is a partnership which is focused on community involvement and decision-making, including educating folks so that they can have meaningful input into chemicals reform.
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Arthur Lee
1/5/11 11:34 AM
[jump to parent] in reply to Lin K.
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The Care Program
No I was not aware. Thanks. We are a member of the "...underfunded..." club.
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James Cooper
1/5/11 09:21 AM
[jump to parent] in reply to Arthur L.
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Industry Employees
Please consider the fact that industry employees are neighborhood folk too and can serve as valuable resources for information about chemical facilities. Dismissing industry employees outright can lead to one-sided information and not a complete multi-stakeholder dialog.
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Active Panelist Timothy Malloy
1/5/11 09:18 AM
[jump to parent] in reply to Arthur L.
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Role of Universities
I am curious, Arthur, what role you see public universities playing in all of this. Are there good examples of universities and colleges providing resources and support to local communities that may be relevant here?
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Arthur Lee
1/5/11 11:22 AM
[jump to parent] in reply to Timothy M.
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Role of Universities
Some university systems, especially those with medical and health sciences are involved in community based participatory research. I believe that these efforts should be expanded to cover those areas that impact community health. Engaging communities meaningfully is happening. The University of Washington has a center that helps develope academic community partners including those that have been involved with environmental justice. See the attached website for the Community-Campus Partnerships for Health.
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TSCA Reform 18 Replies New
Active Panelist Patricia Beattie
1/5/11 07:04 AM
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Last year, bills to reform TSCA were introduced in both the House and Senate. With the new Congress, new bills may or may not be introduced this year. How critical is TSCA reform to achieving the goal to reduce chemical exposures and potential public health impacts?
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John Kollman
1/5/11 11:59 AM
[jump to parent] in reply to Patricia B.
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Chemical Policy Reform Now
I believe TSCA reform should be the number one priority. Of the 80,000 chemicals now believed to be in commercial use, only about 2 percent have been thoroughly tested as to their toxicity. More attention and support should be given to the introduction of measures requiring manufacturers to conduct sufficient testing to determine the safety of chemicals before they enter the marketplace. The burden of proof (relying more on testing than on structural comparisons) should be on chemical manufacturers to prove the safety of their chemicals. Public health experts and institutions need to become more involved in the effort to pass such measures, e.g., the Safe Chemicals Act of 2010, so that chemical reform can become a reality in this country, as it already has in Europe.
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Randall Brinkhuis
1/6/11 02:58 PM
[jump to parent] in reply to John K.
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TSCA reform alone is not enough
Many people do not realize how many chemicals are not regulated under TSCA. For example, pesticides and drugs are specifically exempted from TSCA coverage. In the case of "dual-use" substances (i.e. chemicals that could be used in either context) that presents a problem since manufacturers aren't required to report under TSCA if they're used in a non-TSCA setting.

Another problem is that there are many more chemicals out there than people realize (see paragraph from OSHA Hazard Communication Standard below--though that does refer to "chemical products"--and please note that was from 1994). And as the agenda and workgroup reports note, no one is exposed to a single chemical at a time.

But 80,000 chemicals is misleading for a couple of reasons (in both directions). Many of those chemicals are no longer manufactured. On the other hand, no one really knows what some of these "chemicals" really are. Yes, that's true. We don't necessarily know what chemicals are actually present in petroleum streams, natural products, and reaction byproducts.

And for many chemicals it's not the manufacturing site where they're exposed; it's in their homes after they've purchased a product. At minimum people should be able to know what's in the products they buy.

Another reason why TSCA reform won't in and of itself be enough is that many chemicals people are exposed to aren't actually manufactured. Some are naturally occurring (e.g., asbestos) while other chemicals people are exposed to are actually degradation products, contaminants, or metabolites. Pharmaceuticals and personal care products are showing up in water. Some of those could be identified during life cycle assessments, but others would be harder to predict depending upon the conditions in which they were used.

__________________

From OSHA's Hazard Communication Standard
59 FR 6126, Feb. 9, 1994

According to the National Institute for Occupational Safety and Health (NIOSH), there are as many as 575,000 hazardous chemical products in these workplaces (48 FR 53323). Based on the growth rate of the chemical industry with regard to new products, this number may now be as high as 650,000. Chemical exposures occur in every type of industry (52 FR 31858). (See also Exs. 4-1 and 4-2.) In fact, workers typically experience multiple exposures to numerous industrial chemicals at one point of time or over a long period of employment. 48 FR 53323.
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James Cooper
1/5/11 08:44 AM
[jump to parent] in reply to Patricia B.
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Reform: A Matter of Interpretation
I think industry generally agrees that TSCA could be improved to provide more clarity, certainty and transparency in chemicals management. There is a common misunderstanding, however, that TSCA addresses all aspects of chemicals management, such as labeling, ingredient disclosure, workplace safety and other important issues. TSCA can help EPA make information about chemicals publicly available and allow EPA to manage how chemicals are used, but there are many other federal laws that apply to chemicals management as well. Some proponents of TSCA reform need to better understand the history of chemicals management and all of the different laws that apply before making a snap judgment that TSCA needs a dramatic overhaul.

There are some who think that EPA should be allowed to "manage" whatever it wants whenever it wants. Giving EPA carte blanche authority is not the answer. Appropriate chemicals management should be based on the hazards of chemicals AND the potential to which people or the environment could be exposed to those chemicals. Chemicals management is a complex subject and creating policy in this area should be afforded an appropriate amount of time to create something that will work and not drive more manufacturing jobs overseas. Chemicals management must also protect American intellectual property. If a multi-stakeholder approach were used to develop a rational framework for chemicals management, it would maximize the chances for successful TSCA reform. Both political parties should strive to balance the need for pertinent chemical information and appropriate management of chemicals with the need for innovation, a strong manufacturing base and good-paying jobs.
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Jennifer McKinnis
1/5/11 09:28 AM
[jump to parent] in reply to James C.
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Who decides "Hazards of Chemicals?"
You have some excellent insights. The laws regarding labeling, etc.should be addressed as well. My concern is who sets the bar for determining which chemicals are hazardous? As you are a chemist, and have studied extensively to get where you are, you and others like you, undoubtedly feel that you are more qualified. Perhaps you are. I don't know. Would you be basing you assessment on the "norm, or median?"

I am concerned because I am so chemically sensitive that even parts per billion harm me. Things that you might determined based on structured lab analysis, as non-toxic, are life threatening to me. Literally. This too is scientifically validated, with factual evidence.

I think this perspective needs to be considered in any kind of "balanced chemical management." Persons with Chemical Sensitivities are conservatively estimated (2002) at 40% of the population, and the rates where rising aggressively. Dr. John Greene, children's neuro-degenerative disease specialist reported at DAN 2006 conference that, "6 out of 10 children have a neurologic condition due to toxins. We are no longer the minority." therefore, shouldn't the chemically sensitive be considered the norm and "hazards of Chemicals" accessed on that basis?
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Geri Aird
1/5/11 10:54 AM
[jump to parent] in reply to Jennifer M.
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Increased "chemical sensitivities" in adults and children
This comment resonates with me. I and members of my family are very sensitive to chemicals we are exposed to in everyday living. For seven years, we lived in a house trailer with bad drinking water in an area of vertical gas drilling and storage.

We moved out years ago, but still have muscle weakness and tiredness as the first feelings when entering a "new" building and shopping in a clothing or furniture store. Food sensitivities are another issue. Certain level of air pollution produces tongue tingling and breathing difficulty.

I'm hoping that if I continue to live in New York State, I can be spared from the chemicals that come with natural gas drilling.
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James Cooper
1/5/11 09:43 AM
[jump to parent] in reply to Jennifer M.
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Chemical Sensitivity
I agree that chemical sensitivity is an important consideration in overall chemicals management. The difficulty lies in how to determine who is sensitive and to what. It's a similar dilemma faced in medicine. How can a doctor know if a patient will react to a certain medicine? The answer seems to be: it depends on the patient. Although many people have considered this dilemma, I've not yet heard of an effective way to incorporate it into an overall policy, even within the medical community.
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Active Panelist Lin Kaatz Chary
1/5/11 09:17 AM
[jump to parent] in reply to James C.
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Management vs prevention
I think that James has raised a critical point with regards to expectations and intentions for TSCA reform. It would also be a mistake to assume that the serious critiques of TSCA coming forward from many communities are the result of snap judgments -that perspective might also be considered a snap judgment itself! But more importantly, the issues of what the role of TSCA, as well other federal regulations, is in chemicals policy is really the crux of the discussion. On the one hand, there is a perspective that there are no "bad" chemicals, and policy/regulation should focus on management of exposures. The public health perspective, I believe, is that management is appropriate only when prevention fails, and our chemicals policy should promote - among many other things - the ability to discriminate between chemicals which are understood to be harmful to human health and the environment, and those which can be used with greater confidence of less harm.
Also, James, given your comments about preserving American jobs in the chemicals industry, which is certainly a priority, can you comment on how you think REACH and other international regulations have an impact on this issue? Where do you think this concern fits in with the current recommendations?
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James Cooper
1/5/11 09:57 AM
[jump to parent] in reply to Lin K.
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Prevention
Sorry if I'm over-generalizing about proponents of TSCA reform, but it's been my experience in public discussions that many people who support drastic overhaul point to issues that are covered under other laws and not TSCA. I agree that prevention is key and have always been a big supporter of the Pollution Prevention Act. I find it disappointing that the EPA staff who work so hard to implement the P2 Act are given so few resources. Programs, such as Design for the Environment, produce tangible results and should be held up as a model in true multi-stakeholder problem-solving.

The European Union, and a handful of large, multinational companies that have to comply with REACH, have been advocating the adoption of REACH in other regions "to level the playing field." It is in the economic interests of the EU and those companies to compel the adoption of REACH worldwide because if other regions do not adopt a REACH-like system, the EU will be at a competitive disadvantage, due to the cost of testing and other REACH compliance.
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Active Panelist Lin Kaatz Chary
1/5/11 10:19 AM
[jump to parent] in reply to James C.
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REACH and jobs
I think it will be really interesting to see how this plays out - and whether the trend will be to adopt REACH-like regulations elsewhere, some of which has already started. Given your observations about this, how do you think it relates to keeping jobs in the U.S.? I think this is an issue which, while not addressed directly in the recommendations, is clearly a critical corollary.
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James Cooper
1/5/11 02:01 PM
[jump to parent] in reply to Lin K.
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REACH
The issue of chemicals management in general affects most manufacturing because chemicals are used as raw materials and processing agents throughout the economy. As the price of raw materials rise, so does the cost of goods. Many raw materials are commodities, so it's almost impossible to pass the cost along to customers. Regions that offer cheap raw materials tend to be favored by manufacturers over regions that do not.

I think the jury will be out for a while on the economic effects of REACH. The EU has other economic problems, so it will be difficult to discern cost/effect. I do believe, however, that if other regions do adopt REACH-like systems, it will place the EU in a more competitive situation than if they don't.
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Janet Clark
1/5/11 09:47 AM
[jump to parent] in reply to Lin K.
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Level playing field question
This is a thoughtful response Lin, and I would also like to hear how we can advance national policies that quickly gain the trust of all stakeholders so that companies do not experience a patchwork of state policies frustrated with ineffective federal policy. Related to this is how to avoid compliance uncertainty during a full and careful (and protracted) dialog about TOSCA reform. This may give advantage to the status quo and shorter term industry goals, but is bad for us all in the longer term.
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Facilitator Gail Bingham
1/5/11 09:02 AM
[jump to parent] in reply to James C.
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consumer information
You mention that TSCA doesn't address labeling or ingredient disclosure. These are topics others have raised, and I'm wondering what your thoughts are about whether and/or how to improve information available to consumers. Specifically, we'd appreciate your comments about recommendations 5.2 or 5.4 -- are these helpful, do you have concerns or suggestions for improvement? (see the "information for decision making" discussion in topic area three)
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Doug Farquhar
1/5/11 07:30 AM
[jump to parent] in reply to Patricia B.
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TSCA Reform
The chemical industry may seek to move forward with some reform, working with a more sympathetic Congress. They still must deal with REACH and WTO requirements, plus rules from the states of CA, ME, MN and WA which make their work more difficult. Streamlining requirements would benefit the chemical industry, which may provide an incentive to work to reform parts of TSCA. I am doubtful, however, that a complete rewrite of TSCA will occur.
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Active Panelist Pam Eliason
1/5/11 08:20 AM
[jump to parent] in reply to Doug F.
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States activities
Because changing federal chemicals policies has proven to be cumbersome and slow, many states have taken the initiative to create more proactive chemicals policies that allow them to restrict the use and sale of chemicals of high concern. Washington, Maine, Oregon, Illinois, Michigan, Minnesota, Massachusetts, Connecticut, California ....

While there is work in progress to have the approaches taken by the various states correlate and complement each other ... but a federal approach would certainly go a long way.

I'd love to hear individual states comment on how they see this moving forward and what they might suggest.
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Active Panelist Gail Shibley
1/5/11 08:40 AM
[jump to parent] in reply to Pam E.
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states struggle... but are determined
my experience is that both executive & legislative branches of state governments are struggling with how 'best' (efficiently, effectively) respond to yawning gaps in federal protection. some states are joining together either formally or informally to deal w/ policy, process, science and and other issues. i see this continuing and increasing -- personally, i believe it's been this state-level effort that's prompting at least discussion of tsca/chem reform on the hill.
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Facilitator Gail Bingham
1/5/11 08:57 AM
[jump to parent] in reply to Gail S.
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"states as labs"
Gail/Pam/others.... as the states talk to one another have you identified any specific policies or approaches at the state level (in addition to TURI in Massachusetts) that should or could be considered in TSCA reform?
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Doug Farquhar
1/6/11 08:07 AM
[jump to parent] in reply to Gail B.
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States
States are providing reform where Congress has failed to act. TSCA (and chemical safety) reform has been stalled in Congress, but that does not mean the problem has gone away. Constituents still petition their legislators to do something about chemicals in their community, and if Congress will not act, the states will.

And state policy will not be uniform (TURI in MA v. response in CA) placing additional pressure on industry to design a product that is legal in all jurisdictions. States are performing chemical reform, albeit not TSCA reform.
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Jaime Steedman Lyde
1/5/11 09:46 AM
[jump to parent] in reply to Gail B.
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States as labs
California's Green Chemistry Initiative has been a huge step forward in California, starting with a Green Ribbon Panel that included stakeholders from all different sector contributing their thoughts and expertise on how to proceed. It has taken several years to come to fruition but it is a level headed cooperative aproach worthy of watching.
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Active Panelist Elise Miller
1/5/11 07:09 AM
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An overview comment re: the draft of Chapter 1:
In this chapter, three recommendations are considered "primary" and the others "additional." What you will find, however, is quite a bit of overlap between a number of the recommendations. For example, recommendations 1.1, 1.4, and 1.7 are all, in essence, underscore the need for: the development of safer alternatives (for which there should be even stricter guidelines to determine if they are indeed safer) through a number of mechanisms, including: implementing policy incentives (e.g. TSCA reform); investing in research that promotes green chemistry and development of health-focused substitutes; increasing cross-sectoral collaboration with all parties that are involved in and/or impacted by environmental exposures; and requiring research and decision-making to consider the health impacts on children and other vulnerable populations. There may be some utility in condensing some of the recommendations, and ensuring specific recommended actions are more succinctly stated.
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Bill Osmunson DDS, MPH
1/5/11 09:16 PM
[jump to parent] in reply to Elise M.
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Chapter 1.1 Recommendation.
1.1 add the words, "and will not promote or recommend drugs unapproved by the FDA CDER."
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Active Panelist Gail Shibley
1/5/11 12:26 PM
[jump to parent] in reply to Elise M.
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combine/coordinate 1.4 + 1.7
hi elise - a belated reply to a part of your very helpful comment: i share your view that 1.4 and 1.7 (in particular) cover much the same ground; i've actually suggested an edit that combines them without (i hope) diluting or over-generalizing their focus.
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Active Panelist Elise Miller
1/5/11 02:23 PM
[jump to parent] in reply to Gail S.
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Chemical Policy Reform
Thank you, Gail, for your suggested edits. We welcome specific refinements (and enhancements) of the recommendations.
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David dow
1/5/11 08:54 AM
[jump to parent] in reply to Elise M.
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Recommendation 1.7 on Use of Precautionary Approach to Protect Human Health
Since there is a poor understanding of the human health effects associated with contaminants of emerging concern (endocrine disrupters, pharmaceuticals and personal care product; etc.), we need to utilize a precautionary approach for situations in which these chemicals (or their toxic metabolic intermediates) occur in environmental media (water, soil, air, wildlife) and have exhibited impacts on biota or potential for bioaccumulation through the food chain. Since the biological availability of cecs and their fate/transport are poorly understood, we need to use precaution in the face of environmental uncertainty in regards to their effects on wildlife.

For example a number of EDCs induce the female egg protein, vitellogenin, in the serum of male fish in freshwater ecosystems which should raise a flag that a precautionary approach should be considered for these EDC components or mixtures. In many cases, the blood serum vitellogenin biomarker studies don't identify the EDCs that cause this impact, so that might need to use chemical analysis for detectable EDCs and use laboratory databases to infer the potential contaminants of concern (coc). It is certainly easier to use biomarkers to detect cec effects on biota in aquatic ecosystems than to use laboratory toxicity tests of individual chemicals. Since there is some uncertainty for EDCs on the dose/response relationship in toxicity bioassays in the laboratory, indirect approaches such as risk assessment or vulnerability analysis may be required (recommendation 1.8).
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Judith Murawski
1/5/11 10:45 AM
[jump to parent] in reply to David d.
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Precautionary approach is essential and justified
I won't rehash David Michael's "Doubt Is Their Product" book at length here, but anyone who has read it (or works in public/occupational health) knows that the system regulating chemical exposures in the US is broken, and specifically how industry has very effectively dismissed the "precautionary approach" as unnecessary because they do not want to be regulated, and so instead they fund research that is designed to find no problem, or at least leave the question open. Many agree that monied interests shape policy (or the lack of policy) on chemical exposures in the US, but what to do about it?

Until the majority of researchers that investigate the health impact of exposure to chemicals is properly separated from the industry that develops said chemicals, this will not change. Also, regulators must make more of an effort to systematically collect documented reports from the public (now typically dismissed as "anecdotal") and must consider the consequences of not taking a precautionary approach. Regulators must focus on prevention not on defining "safe" exposure limits that are largely based on an oversimplified dose-response model and does not account for interindividual differences in genetics, liver function, synergistic or antagonistic exposures, chemical mixtures, expousure history, health status, etc.

As an example, the air supply system on commercial aircraft sometimes gets contaminated with toxic oil fumes. Industry has avoided regulation, in part by funding studies in which test animals ingest engine oil and do not exhibit serious symptoms, enabling the oil manufacturers to claim that their products are safe. But crew/passengers are not ingesting room temperature oil, they are inhaling pyrolyzed oil-- the industry studies do not reflect exposure conditions. Further, the two published toxicity studies that test the impact of inhaling pyrolyzed engine oil both conclude that the products are highly neurotoxic. Further, aviation authorities around the world have recognized that pilots who inhale oil fumes inflight can be impaired to the point that flight safety is compromised. But industry dismisses this growing stack of formal investigative reports as "anecdotal" and claims that, because the concentration of one component of a chemical mixture is below the PEL in some cases, the chemical exposure can not explain reported symtpoms, even though there is no other explanation. And so, there are no regulations to prevent oil fume exposures on aircraft: no requirements for engine oil companies to use less toxic additives; no requirement for airlines to train crewmembers to recognize and respond to fumes; and no requirements for manufacturers to install filters and monitors in the air supply systems on aircraft. People who report illness are dismissed. Flight safety concerns are brushed aside. Industry says that there is too much uncertainty to regulate, and the regulators have agreed with them.

In summary: we need regulators to provide the public with a means to report problems, fund independent researchers, properly critique studies that are funded by monied interests especially, and develop and enforce preventive measures instead of PELs.
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Kyle Dotson
1/5/11 01:07 PM
[jump to parent] in reply to Judith M.
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Financial support for the ACGIH TLV process would efficiently advance public health
Like the previous commenter, I will also not rehash David Michael’s book, but I would not choose the precautionary principle as the best approach as it pertains to the workplace. According to Wikipedia (OK, isn’t it the go-to source of all generic knowledge these days?) the precautionary principle states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking the action. However, in the workplace in 2010, there is much that we already have scientific consensus on and it would seem that it would be better to spend a little more money helping to solve the problems that we already know about rather than to spend more to look for new problems.

It has been my experience that real, widespread and lasting prevention is only built upon a foundation of science-based knowledge. While both real risks can legitimately initially surface as phobias, science either proves up the risk or doesn’t. There are so many substances that we already have good data on; shouldn’t we be focusing on the risks that we already know are real? I am not suggesting we should ignore new potential risks. The focus on nano-materials by NIOSH is excellent. But the OSHA PELs have been in shambles for decades with only a few really reflecting the current science. AIHA has been pushing for years for OSHA to update the PELs and to OSHAs credit they have finally at least gotten together an internal group to discuss it. But let’s face it; OSHA has more pressing and maybe more important issues such as I2P2 to deal with.

Industrial hygienists that have spent time working for workers compensation insurers know that the most profound “chemical” exposures occur not in the Fortune 500, but in the mom and pop shops across America. (It’s in quotes because occupational diseases such as deafness from noise exposures need love too). To address these issues, we first need up-to-date Exposure Guidelines for MORE substances based upon good science. The ACGIH has been producing those for nearly 70 years. But they are now severely hampered in this critical task by inadequate funding.

Such funding action would benefit no budget or staff of any governmental agency or private industry, so alas, it probably can’t happen. But it sure would advance public health. It would be great of ATSDR or EPA or NIOSH or any other agency that was concerned with public health could find a way to financially support the ACGIH TLV process as an independent developer of exposure guidelines. Because without a real world understanding of what levels are protective of nearly all persons, we don’t have much to base reasonable precautionary society-wide preventative measures upon.
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Audrey Adams
1/5/11 09:46 AM
[jump to parent] in reply to David d.
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Precautionary Approach is essential
There is an epidemic of autism and these kids are the environmental "canaries". As a society we can no longer afford NOT to assume a chemical is dangerous until PROVEN SAFE. Everyone agrees that there are "environmental factors" contributing to the frightening rise in autism, but when there are so many possible culprits interacting with each other, pointing to individual chemcials as the cause is pointless.

I am moderately chemically sensitive, but my autistic adult son is horrifically chemically sensitive. My genetics may have left him susceptible, but the lack of very strict environmental laws (and lack of enforcement of those we do have) may have made the world of difference to a lifetime of disabilty.
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Mary Harper
1/5/11 11:59 AM
[jump to parent] in reply to Audrey A.
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...and let's include adult onset illnesses as well
In addition to mounting evidence that there is an environmental link in the dramatic rise in incidence of childhood autism and autism sydrome illness,there is a clear link to the development of Parkinson's Disease and exposure to neurotoxins found in pesticides. The labeling concerns expressed in a different thread are valid here as most say things like "use as directed" when they need to say "use of this product may result in brain damage in yourself and your children".
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Amy Bates
1/5/11 08:37 AM
[jump to parent] in reply to Elise M.
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Chapter 1 Considerations
Chapter 1 Considerations:

The featured recommendations need to be expanded to more intentionally address the disproportionate burden on under-represented communities. For example, in recommendation 1.1 the use of alternative “less-toxic” chemicals is proposed. The interaction of these alternatives needs to be more thoroughly explored to lessen the potential for unintended consequences. Too, the removal of toxic substances tends to equate to a relocation of these hazards to areas wherein under-represented communities are present (hazardous waste sites, etc.). During the process of implementing the use of alternatives, the proper location and disposal of toxic chemicals must be considered to avoid increasing the burden (and associated risk) placed upon under-represented populations resulting from the exposure to these substances. Recommendation 1.2 should include an increased priority for eliminating toxic exposure based upon burden distribution. This could mean incorporating stronger penalties for further impacting disproportionately burdened areas. Recommendation 1.3 focuses mainly upon child health. I agree that protecting children from disruptions in their development is critical. I would add that there are other critical populations that must also be considered to include pregnant mothers, those with compromised immune systems, the elderly, etc.
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Barbara Warren
1/5/11 09:50 AM
[jump to parent] in reply to Amy B.
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Focus on Children
I agree with a focus on Children, but there should be a separate item focused on other vulnerable popultations such as EJ communities. It is not adequate to merely add vulnerable populations as an afterthought to Recommendation 1.3.
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Active Panelist Elise Miller
1/5/11 12:01 PM
[jump to parent] in reply to Barbara W.
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Focus on Children
I very much agree with you, Barbara. And 'vulnerable populations' can be such a nebulous term. Perhaps we should use more specific examples, like EJ communities (or even more explicitly 'communities experiencing environmental INjustice'--i.e. low income/minority/already-impacted communities)? In addition, those in the developmental disabilities sector as well as those with chemical sensitivities and/or chronic illnesses have suggested those groups should also be included as "vulnerable populations." In short, it seems like defining what we mean by 'vulnerable populations' would be useful, so it doesn't appear to be an afterthought. Of course, if we actually did protect ALL children, starting in utero, we would be taking a huge step towards eradicating environmental injustice--but I realize (sadly) that's not likely to happen any time soon.
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Active Panelist Gail Shibley
1/5/11 08:49 AM
[jump to parent] in reply to Amy B.
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thoughts?
re 1.1: how can we appropriately balance the need you point out to make sure we're not jumping from the frying pan to the fire w/ the need to move forward now and not (continue?) study/ing for another 30 years? would a 'green screen' type of analysis be sufficient?

re 1.3: the leadership council discussed this concern -- i.e., how to be both specific and inclusive. in order to adequately address fetal development & children, perhaps adding another recommendation that provides similar focus on other vulnerable/susceptible populations?
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Jennifer McKinnis
1/5/11 10:57 AM
[jump to parent] in reply to Gail S.
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Green screen type analysis
A " Green Screen type of analysis" seems to me to be an important first step. There are many more data basis similar to this that can be accessed to improve the process as we go along.

Many of the toxic substances in use today have record of causing harm that began 60 years ago. 30 more years of study will only cost millions more lives lost to death and disability.... not to mention the negative economic and social impacts. These factors aren't currently being accessed in the decision making process. When they are, the balance definitely swings to a health and environment protective approach.

In my personal opinion, we are already in the fire, it's time to get out.
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Jennifer McKinnis
1/5/11 09:39 AM
[jump to parent] in reply to Gail S.
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Clarification?
Gail, I'm confused as to what you are saying needs to be studied for 30 more years? Please clarify the reference, "green screen."

Re: 1.1 less toxic substances and/or practices, there are already numerous proven alternatives available.
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Active Panelist Gail Shibley
1/5/11 12:38 PM
[jump to parent] in reply to Jennifer M.
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clarification
sorry, jennifer, if i'm confusing folks. first, i was inquiring how we could/should pursue the earlier comment to more fully test whether would-be alternatives are truly safer or not, particularly in combination/s. the reference to '30 years' is recognizing that in the (now almost 45) years since tsca was enacted, epa has taken action on 5 substances ... and at least one of those literally required an act of congress. in other words, i don't like the regulatory hole we're in and want to help fashion a future that we can move toward today and NOT have to wait yet more decades into the future.

my reference to 'green screen' regards cleanproduction.org's opensource tool to assess less hazardous substances. i'm no expert on it, but am intrigued by such possibilities. The URL for more info is attached.

hope that's helpful; sorry again for not being clear.
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Active Panelist Lin Kaatz Chary
1/5/11 10:02 AM
[jump to parent] in reply to Jennifer M.
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The Pharos Project (URL)
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The Green Screen
Hi Jennifer. For more information about the Green Screen, a tool for assessing chemical hazard, you can check out the website of Clean Production Action who developed the Green Screen. The URL is attached and the website has a lot of great information. There are a number of tools being developed to address assessing chemicals, some better than others. With regard to safer building materials, you might also want to check out the Pharos project website at the attached URL. Let me know if you are interested in hearing about others.
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Jennifer McKinnis
1/5/11 10:47 AM
[jump to parent] in reply to Lin K.
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Thank you!
I checked out both web sights, good reference.
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Facilitator Gail Bingham
1/5/11 08:32 AM
[jump to parent] in reply to Elise M.
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specificity
Please help us maintain specificity and clarity about who should take what concrete actions so that it doesn't become so general that everyone agrees but no one acts.
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Active Panelist Julie Fishman
1/5/11 08:24 AM
[jump to parent] in reply to Elise M.
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Chapter 1 recommendations
Thanks for this comment, Elise. I had noticed this as well. During this next phase of review of the Action Agenda, we will be looking for just this sort of overlap within chapters, and also across chapters. We will highlight such recommendations for discussion by the Leadership Council on the chapter calls that will occur in February, and any remaining issues can be discussed at the in-person meeting in March.
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Jeannie Economos
1/5/11 07:10 AM
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Pesticide policy, as well as chemical policy in general, should be converted from a risk assessment basis to a health and environment protective basis. Risk assessment devalues human lives and ecosystems for supposed beneficial economic outcomes. Too often, however, years and decades later, pesticides and chemicals that were approved for use as 'safe' are found to have long term health and environmental consequences. An example is methyl bromide. After decades of extensive use of methyl bromide, it was later discovered to be a major contributor to ozone depletion and at least parlty responsible for the hole in the earth's protective ozone layer. However, in an effort to find a replacement pesticide, and in spite of extensive research worldwide on non-chemical alternatives, EPA recently registered a more harmful pesticide - methyl iodide - for use in agriculture. While not impacting ozone depletion, methyl iodide is so toxic that 54 noted scientists signed on to a letter to EPA against its being approved. It has been shown to cause birth defects, thyroid cancer, and is a groundwater contaminant. Farmworkers are especially at risk from the use of methyl iodide in agriculture. Moving away from a risk assessment based approval process would have made it unlikely that such a dangerous chemical would achieve EPA registration. Farmworker health risks from pesticide exposure are often 'under the radar screen.' Economic benefits to agriculture are balanced against the lives of men, women and children that work in the fields and greenhouses. Their lives must be given greater value, and the current risk assessment process fails to do that.
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Active Panelist Lin Kaatz Chary
1/5/11 11:25 AM
[jump to parent] in reply to Jeannie E.
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Pesticides, other toxics and the regulatory structure
Jeannie, I totally agree with you, and would like to point out an issue that we tried to address in our recommendations on policy and practices. Probably most people in this discussion know that pesticides are not covered under TSCA, but under their own legislation, FIFRA. This is another example of the fragmentation of laws and policy governing chemicals which has some benefits, but also many drawbacks. For one thing, it tends to keep the discussion about toxics policy reform fragmented as well. While on the one hand it is important to have a regulatory regime which focuses on pesticides specifically in all the complexity required, at the same time, it seems to me we also need some kind of overriding, unifying chemicals policy which incorporates and addresses ALL aspects of chemicals use and exposure.
We tried to address this in our recommendations by promoting the development of mechanisms that break down "siloing" and promote interactions both between and within agencies that address toxics - that is, EPA, Agriculture, Food Safety, CDC, and so forth. Regulations such as FIFRA, TSCA, RCRA and others have to be see as all part of a unified and coherent policy approach under the rubric of public health protection and prevention. Right now the focus is on managing what are known hazardous substances, when it should be on figuring out how to work jointly where possible to prevent the use of those chemicals, with reliable mechanisms in place to assess substitutions and alternatives to make sure the "cure" isn't worse than the disease. The methyl iodide situation is a perfect example of the critical need for a more wholistic approach which is based on prevention, and of the abject failure of current methods.
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Elizabeth O'Nan
1/5/11 10:09 PM
[jump to parent] in reply to Lin K.
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CHANGES IN PESTICIDE LAWS
One change that I feel would benefit the public would be elimination of all "confidential business information" corporate protections. This does nothing to keep secret formulas secret as reverse engineering methods can reveal these product secrets. What the laws do is intimidate EPA employees and prevent them from testifying on behalf of chemical injury plaintiffs. The laws also keep poison victims from discovering the exact chemical that caused their injury. This is especially true if the actual injury is caused by so called "inert ingredients" that may be more toxic that the "active" ingredients. I have found that even in emergencies few doctors are willing to sign threatening documents to obtain this information. This is another area that needs to be homogenized with other programs on toxic materials.

"Confidential Business Information" laws are simply another way to keep the public ignorant about their danger.
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Jennifer McKinnis
1/5/11 12:29 PM
[jump to parent] in reply to Lin K.
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FIFRA has no protection for citizens
Thanks for making these comments Lin. I've read FIFRA, when I was initially looking for help in preventing additional pesticide assaults. I couldn't find anything in the law that protects the consumer or citizen. It wasn't written for that purpose.

We need a definitive law that recognizes the fact that misuse of toxic chemicals should be considered assault with a deadly weapon. It should be considered a criminal offense. Currently, even intentional drift of pesticide, with intent to commit bodily harm, is considered a civil crime and is next to impossible to bring to court, or get state or local authorities to act on.

Toxic chemicals kill and maim more people than hand guns and they should be treated in a similar manner...
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Jennifer McKinnis
1/5/11 08:39 AM
[jump to parent] in reply to Jeannie E.
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Risk Base vs. Health Base
I agree. As a person who is severely disabled by pesticide poisoning, I experienced this first hand. I was repeatedly told by governmthat officials that my life didn't matter - that I was expendable " for the greater economic good of the community." I received the most appalling discrimination and refusal to protect my life because my disability was based on pesticide poisoning and in my state, "we are an agriculture based economy. They actually said to me, "a few have to die for the good of the many." That short-sighted view is responsible for the disability and deaths of, millions of people, world wide. Region 10 ADA's office says that "people with chemical sensitivities are the fastest growing segment of the disabled population.

USC Air Quality Research station stated, in a report on air pollution out of China that, any substance dispersed into the air, circumnavigates the globe in 3 weeks. These poisons are accumulating in our soil, plant tissues, livestock, citizens, surface water and groundwater. We must change to a health and environment protective bases for policy making, because the facts show that our current risk bases accessment is harming us all.
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Audrey Adams
1/5/11 09:33 AM
[jump to parent] in reply to Jennifer M.
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Chemical Poisoning Hurts Everyone
Jennifer, you are not alone. There is an enormous and rapidly growing population of autistic children and adults who, like you, are severely affected by chemicals. Their reactions to chemicals are often more disabling even than the autism. But whether you are disabled when an adult or as a child, the financial drain on governments and society is horrendous. The lack of strict policies on chemical exposures of all kinds affects every single one of us. I love my autistic son dearly, but the lifetime financial and emotional impact often leaves families in ruin. For my guy, chemical exposures dramatically increase his autistic behaviors, increase his care needs and decrease his ability to work or help with his own care needs. Anyone who thinks that you, Jennifer, or my son are "expendable" for the "greater economic good" have not considered the whole economic impact.
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Ruth Kerzee
1/5/11 08:05 AM
[jump to parent] in reply to Jeannie E.
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Pesticide use laws.
I agree with everything Ms. Economos has stated in her comments. Not only is regulation letting people and the environment down by allowing highly toxic and destructive products out into the market for professional use, it is completely inadequate at the consumer level as well. In my years of experience working with the public around pesticide use issues, I feel confident in stating that when a products label reads, "Safe if used as directed," or, in the case of general consumer pesticide products, "It is in violation of Federal law to use this product in a manner inconsistent with its labeling," you can be pretty sure these directives are being ignored.

The Federal government needs to do a better job of regulating these products so consumers understand the real dangers they pose to their health, the health of their children and pets, and the environment. In addition, products that are consistently used in a 'manner inconsistent with labeling,' need to be taken off the market. One such pesticide product that immediately comes to mind are pesticide foggers. These are the 'unsafe at any speed' poster child for pesticide products. Let's start there.
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Mari Eggers
1/5/11 02:51 PM
[jump to parent] in reply to Ruth K.
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Enforcement of pesticide use laws
I couldn't agree more strongly with Dr. Economos and Ms. Kerzee. In our community listening sessions, inappropriate and illegal uses of pesticides was one of the top three community concerns. We heard how the local company which sells pesticides to farmers and ranchers ignores the requirement to only sell restricted pesticides to people who are certified to use them, how farmers are simply pouring the pesticide into the ditches that flood irrigate their fields, how farmers can't do the math to correctly calculate the right dilutions, how homes are directly sprayed even though they are beyond the crop fields, how the pilot who sprays along the RR tracks keeps right on spraying wherever the tracks cross the river, the list of community complaints goes on and on. Hence any risk assessment based on agricultural pesticides being used "in a manner consistent with the labelling" is invalid. Dr. Economos, can you suggest a recommendation that would take into account the comments in this discussion?
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Active Panelist Gail Shibley
1/5/11 12:50 PM
[jump to parent] in reply to Ruth K.
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action agenda recommendation?
thanks to jeannie, ruth and others for raising this. do you have a suggestion for making sure this is adequately addressed in the 'action agenda?' you'll note chapter 1's recommendation calls out tsca reform, but i don't think there is reference to fifra, ppa, sdwa, cpsa, ffdca or other laws that impact human exposures to chemicals.
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David Dorch
1/5/11 08:34 AM
[jump to parent] in reply to Ruth K.
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Pesticides in Communities
We are currently fighting a landfill in Greenwood South Carolina. Many harmfull pesticides were found, 4.DDE,4.DDT,alpha-chlordan,dieldrin,endrin ketone,gamma-chlordan,and methoxychlor. Any many other chemicals. Many three times the EPA Level. Instead on helping the people, the Town hired Davis& Floyd a enginering,architecture, and enviromental&Laboratory service to contest the finding. The City of Greenwood with the guidance of The South Carolina Department Health and Enviromemtal Control are saying the Landfill , pesticides,chemicals and gargarge dump, does not exist. The people that have lived in the community for decades witnessed tons of garbage being trucked and burned in there community. There are many that are sick in the community. Many of the people are children and elderly. They just what to clean the top of the landfill off and leave the people. Make the community look beautiful on top. Like putting flower on a grave! Does any one have any sujestions for us? We need help.
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Michele Louros
1/5/11 08:32 AM
[jump to parent] in reply to Ruth K.
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Pesticide use laws
I agree and has anyone heard of "Morgellon's" a disease which may be caused by pestiside or exposure to toxic molds fungas? Why has there not been any help to those exposed and suffering?
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MARK RUSSELL
1/5/11 03:12 PM
[jump to parent] in reply to Michele L.
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PREVENTATIVE APPROACH
When you run a Business---You base Your Business Model on Profits and Losses.

What would it take to prevent Chemical Poisoning in the Farm Fields?

A) Filtration Dust Mask?---Maybe
a Cost of $.25 cents
B) Double Filtration Dust Mask---Maybe a
Cost of $2.50---$15.00
C) Charcoal Active Filtration Mask---Maybe
a Cost $10.00--$25.00
D)
E)
F)

Many of the solutions might Lie in Prevention the Chemical Exposure and Protecting the Worker. When you explain to a Businessman the Cost Benefit of not being Sued by an Employee with Cancer caused from Chemical Pollution---The .25 Cent Dust Mask is a Great Start. When you give the Businessman the Hard Court Cases and the Potential Liability of Employees that can prove that you got them sick----The Expensive Charcoal Activated Filtration Mask Sounds even Better.
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Monica Becker
1/5/11 07:42 AM
0 AGREED PANELIST RESPONSE NEEDED RESOLUTION NEEDED 0 REPORTED 1. Prevention, Positive Chemicals in products (articles) (URL)
Chemicals in Products project of the U.N. Environment Programme 2009-2010 (URL)
Toxic Substances in Articles The Need for Information (PDF)
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There is a need for greater transparency and education about chemicals in consumer products. Increasing requirements for product labeling is one strategy; compelling product manufacturers to be more transparent through consumer pressure is another. Companies that are required or compelled to disclose the chemical contents of their products, be they cleaning products or computers, become more focused on designing out chemicals of concern.

Attached is a document titled, “Toxic Substances in Articles: The Need for Information.” The report describes the problem of toxic substances in products, with specific examples, and considers the advantages that would result from better information on chemicals in products. The report describes existing efforts to generate and disseminate information about chemicals in products, both regulatory and voluntary initiatives, and provides recommendations for increasing the availability of information to consumers and other important stakeholders.

Please see the attached report.

The report was written to support an international effort to increase availability of chemical information, to use and exposure to hazardous chemicals. The effort falls under the Strategic Approach to International Chemicals Management (SAICM), managed by UNEP. For more information, see the attached website URLs for SAICM articles on Chemical in Products, and activities of the Chemicals in Products project of the UN Environment Programme Division of Technology, Industry and Economics.
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ricky choy
1/5/11 05:14 PM
[jump to parent] in reply to Monica B.
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Toxic Chemicals
There are thousands of articles about hazardous effects of glutaraldehyde & other toxic chemicals used in hospitals for many years now.Still these chemicals are being used & sad to say in our developing country we do not have enough resources to provide health & hospital workers proper protective devices. May we propose that health experts like the WHO & the CDC recommend alternatives to these toxic chemicals. But up to now their use is still being endorsed by them.
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Eugene Blanck
1/5/11 11:43 AM
[jump to parent] in reply to Monica B.
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Public Harm from chemical exposure
Dr. Sanjay Gupta (CNN) testified before Congress about the thousands of new chemicals released into the marketplace with only a fraction having some testing regarding their risk to human health. If the public as a whole are to be test subjects, should they not receive adequate disclosure of their potential risk and compensation if they choose to participate in the trial. And when the public is used, how is the data on these unwitting test subjects compiled? If chemical injury information is supposed to be mined through the medical system in the USA, then the reporting of health problems associated with chemical exposure is seriously under reported. Doctors are afraid to make a chemical injury diagnosis and are rarely trained to be able to make that type of diagnosis.

New chemicals put in the public realm should also have readily available and accurate tests for identification in the environment. Too many chemicals (e.g., perchlorate) remain unidentified until adequate testing protocols exist. How many unknown compounds on GCMS scans are actual chemicals (potentially harmful to human health) that are not being identified as a result of inadequate information?
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Charles Winterwood MD
1/5/11 12:47 PM
[jump to parent] in reply to Eugene B.
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Chemical Diclosure
The natural gas industry has received a disclosure exemption from Congress on "fracking" chemicals with the results that many nearby residents have had their drinking water supplies imperiled.
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Amy Bates
1/5/11 09:01 AM
[jump to parent] in reply to Monica B.
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Greater Transparency on Chemicals in Products
The purpose, proper employment, human and environmental hazards of chemical use must be included in order to ensure transparency. There seems to be a disconnect in terms of the person responsible for the type of chemicals employed, and the person responsible for employing the chemical directly. There needs to be a way to ensure that those responsible for the selection, purchase, and oversight of the use of chemicals is held to a high standard of responsibility for ensuring that those employing the chemicals directly have appropriate access to chemical precautions. This could mean properly translated materials, information written in understandable terms, the demonstration of knowledge, in addition to ongoing training.

Also, a product labeled “safe when used as directed” does not always consider the interaction(s) that are possible based upon the use of multiple chemicals. The precautionary principle is important in these instances.
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Nancy Swan
1/5/11 07:52 PM
[jump to parent] in reply to Amy B.
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I agree, and go one step further
When chemicals are applied or used in public areas, the workers are protected by government regulations, but the public (not employed by the applicator or chemical company) are considered "bystanders."

Example: A small child stands near a pesticide applicator and suffers chemical injuries. The child is a bystander and not protected by existing government and industry chemical safety guidelines and precautionary safety labeling. In my case, the court did not allow the jury to hear government safety regulations and hazardous warnings because those are intended for workers - not bystanders.
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Jennifer McKinnis
1/5/11 10:34 AM
[jump to parent] in reply to Amy B.
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"... When used as directed"
Your comments are spot on. The only thing that I'd like to bring up is that phrase, "... when used as directed." from over site to end user, very few people read the instructions thoroughly. The majority of end users only read the part where it lists what it does, with the focus on will it do their specific job. I.e. Pesticides killing their specific pest with the minimal impact on their pocket book, short term.

Most pesticide labels say, "Do not allow to drift." They will even include further warnings stating ground water contaminates, hazards to people & livestock, food crops and ornamentals. In my experiences, as a toxic injury advocate, I've communicated with thousands of people who have been injured by drift. State and local authorities say there is no law to protect us from this. While I've located and recited these laws to numerous authorities, they "decline" to apply them.

This conversation needs to address this very real issue. There are laws that are already in place that should give us some protection. If the people in positions of authority refuse to act upon them, what actions can we take in this discussion to promote government entities in enforcing those existing and these new recommendations?
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Inactive Panelist John Balbus
1/5/11 10:02 AM
[jump to parent] in reply to Amy B.
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Information on chemicals in products
Please also note that Recommendation 2.3 tries to get at this issue from several perspectives, including enhanced reporting on chemical uses under TSCA and more integrated exposure assessment and monitoring that includes taking into account exposures through consumer products...

Any feedback on this recommendation as written?
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Barbara Warren
1/5/11 08:36 AM
[jump to parent] in reply to Monica B.
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Adequacy of hazard information
All too often hazard reporting covers only the studies that have been done for a particular adverse effect.

In addition to data on health effects that have been studied, we need to include relevant information on all systems, when reporting hazard information. This clarifies the data gaps for the reader.
For example:
Reproductive- No studies
Nervous system- Limited data
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Active Panelist Gail Shibley
1/5/11 10:29 AM
[jump to parent] in reply to Barbara W.
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hazard info
i really like your idea, barbara. one of the struggles i've identified is how to ensure accuracy and completeness in reporting/labeling, while also ensuring readability and helpfulness.

for example, california's prop. 65 has resulted in (among other things), a plethora of signs using the 'safe harbor' language that a particular location or product 'contains a substance known to the state of california to cause cancer' (or something close to that). as a consumer/visitor, i don't find this very helpful. on the other end of the spectrum, pesticide labels overwhelm even an environmental public health professional like me -- while not giving me info on what's NOT there.

that said, it seems we'd need an objective way to determine what "limited data" means, etc. thanks very much for your comment!
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Facilitator Gail Bingham
1/5/11 08:19 AM
[jump to parent] in reply to Monica B.
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Consumer Product Labelling
Consumer product labeling was a theme in the first web dialogue. The text elaborating Recommendation 1.2 about TSCA reform mentions the importance of information on consumer products. Recommendations 5.2 and 5.4 in Chapter 5 also address consumer product information in two different ways.

Do you (or Pat? or others?) have specific suggestions about whether and, if so, what specific actions should be taken to increase information for consumers about what is in consumer products?
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Active Panelist Patricia Beattie
1/5/11 08:08 AM
[jump to parent] in reply to Monica B.
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Transparency - Chemicals in Articles
Monica - Thanks for this information and your comments! I think that many companies as well as consumers believe that if a chemical is incorporated in an article that it poses no risk, therefore, this information is not needed. How can we encourage business and consumers to look further into this premise and consider more critically potential exposures thru a products life-cycle?
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Monica Becker
1/5/11 09:07 AM
[jump to parent] in reply to Patricia B.
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Transparency - in response to Patricia Beattie's comment
Thanks Pat for raising this.

I think there is a lack of understanding on how to effectively communicate information on chemical content and hazards to consumers and how to get consumers interested in being more informed/to be more discriminating on the issue of chemical content/risk.

For the Action Agenda, I suggest that this needs to be a major focus of the work described in 5.2. and 5.5. 5.5 uses the term, “lay-audience and user-friendly format.” I’m not convinced that we truly know what that is.

Some fundamental consumer education/behavior research on this subject is in order. We should involve companies such as SC Johnson, Seventh Generation and Method in these conversations too because they have calculated that it's worth informing consumers about chemical content and they have obviously thought alot about how to communicate that information to their customers and how that affects their top lines.
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Active Panelist Pam Eliason
1/5/11 09:24 AM
[jump to parent] in reply to Monica B.
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Behavioral Research
Thanks for these recommendations Monica. I agree that HOW we convey information to consumers is vitally important. I also like Barbara's suggestions that we include information about where there is a lack of data in consumer products. If companies were required to note that they don't know if a product may impact the reproductive system, for instance, I might very well opt to purchase the product where they can say if they have information. This brings into play the market forces.

It also raises the question of enforcement of statements made, which as we know, is a very variable issue. Again, the need for a federal level approach seems important.
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James Cooper
1/5/11 08:58 AM
[jump to parent] in reply to Patricia B.
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The 4th Branch of Government
Hi Pat - I think one thing that differentiates the US from other regions is our liability laws. That's why laws in Europe and other regions are written differently than in the US. Liability can cause immediate, and sometimes irreparable, economic damage to a company. The US has strong liability laws that protect consumers, workers and others. I'm not saying that information flow should be stifled, but we also have to balance public information with the protection of American intellectual property.
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Paul Orum
1/5/11 11:55 AM
[jump to parent] in reply to James C.
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Disclosure

Re: balancing public information with the protection of intellectual property --

Common sense restrictions on confidential business information (CBI) can effectively limit CBI claims without disclosing CBI.

For example, under the Toxics Release Inventory a company generally cannot keep chemical release information confidential if:
1) The company has already disclosed the information (other than in certain protected circumstances);
2) Another law already requires the company to disclose the information;
3) Disclosure is not likely to harm the competitive position of the company;
4) The information is readily discoverable through reverse engineering.

These requirements keep CBI claims under TRI to well less than 1 percent of all TRI reports.

Similar constructions successfully limit CBI claims for chemical USE information in two states that collect use data (Massachusetts and New Jersey).

Proposed reforms such as up-front substantiation of CBI claims under TSCA can also help limit the unnecessary withholding of information.

In the information age, proactive disclosure of chemical hazard information is a strategy that helps companies avoid circumstances that lead to liabilities.
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Facilitator Gail Bingham
1/5/11 01:29 PM
[jump to parent] in reply to Paul O.
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Recommendation 5.5
Do you have suggestions for modifying Recommendation 5.5 (related to disclosure and confidentiality) or is it fine the way it is?
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Jennifer McKinnis
1/5/11 11:06 AM
[jump to parent] in reply to James C.
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Toxic or not
I get what your saying James, but mandating toxicity rating and declarations on labels wouldn't interfere with intellectual property. They should be required to state if any toxic substances are used in the product or it's manufacture and a simple green/yellow/red bar graph showing the level should be adequate and simple enough. Providing of course that the standard is stringent enough to pass the test for even the most vulnerable populations.
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Monica Becker
1/5/11 09:32 AM
[jump to parent] in reply to James C.
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Government is not the driver -- it's the brands
Thanks James for bringing up the issue of IP (or confidential business information (CBI), which is certainly important in this realm.

The reality is that many consumer-facing companies (e.g., Nike, HP, SC Johnson, Seagate and on and on) are requiring ever more information from their suppliers on the chemical content and potential hazards of the chemicals in the formulations, materials and components that they buy. This information is used by these companies for regulatory reporting requirements (e.g., REACH SVHC requirements), voluntary chemical disclosure programs, green chemistry and other initiatives. Many of these companies will do whatever it takes to get this data, whether it’s signing an NDA, using a third party, or switching suppliers if they cannot get the data that they need.

Suppliers, whether they are large chemical manufacturers or Tier I electronic component or textile suppliers, are starting to figure this out and finding ways to make this work.

Then factor in that Walmart has started to require that vendors of all chemical products (e.g., products that contain a flammable solid, powder, gel, paste or liquid not intended for human consumption), over the counter products, and batteries to disclose, to a third party reviewer, all intentionally added chemicals and their percentages for every product supplied.

As this information begins to flow more freely through supply chains to consumer-facing companies, it will over time lead to greater disclosure to consumers and to safer products.
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James Cooper
1/5/11 01:46 PM
[jump to parent] in reply to Monica B.
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Brand Drivers
You're absolutely right, Monica. The markets have been responding to many of the disclosure issues discussed in this forum. I think that environmental and safety considerations are becoming part of the purchasing equation, along with cost and product performance. The use of third-parties allows this to take place without the appearance of collusion or antitrust.
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Active Panelist Gail Shibley
1/5/11 03:54 PM
[jump to parent] in reply to James C.
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greenwashing vs actionable consumer information
good points, indeed. but what role, if any, does gov't have in ensuring claims like 'green,' 'safe,' 'natural,' 'earth friendly' and others have something other than marketing meaning? using 3rd parties may make a lot of sense, but without coherence or consistency, aren't we asking an already over-burdened public to do homework on what 'x' means when 'y' 3rd party labels something thusly? comments & suggestions are most welcome in helping flesh this out.
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Active Panelist Timothy Malloy
1/5/11 09:24 AM
[jump to parent] in reply to James C.
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Liability Laws
This is an interesting issue, james. I am glad that you brought it up. I worry about placing too much faith in tort liability though as a tool for protection of consumers and workers. There have been a fair number of studies that document the barriers to effective use of the tort system for this purpose. Many of heme speak of the problem of proving causation, and essntial element of a tort claim. This is compounded by the lack of publically available information regarding exposure and hazard for many chemicals, as well the long latency periods that often exist between exposure and manifestation of disease. I have to run right now, but I'll try to get some citations for you. What do you think about such limitations on tort?
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James Cooper
1/5/11 01:49 PM
[jump to parent] in reply to Timothy M.
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Liability
For most companies, the fear of tort is a more powerful deterrent than tort case history. Even if causation cannot be proved, a brand can be quickly and irreparably tarnished in a tort case.
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Jennifer McKinnis
1/5/11 12:01 PM
[jump to parent] in reply to Timothy M.
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Lawyers Specialize
I too found the torte system fraught with barriers. Number one was the preponderance of attorneys that claimed they "specialize." I was told they wanted to get the most money for the least amount of effort, so they only took a certain type of case. One that they could just stamp out.

The second barrier was the cost, I couldn't afford to bring economic disaster on my family, so I was forced to forego justice.

The third, politics. I was informed that if you want to run for elected office in an agricultural community, you don't assist the person who's been grossly injured by misuse of pesticide.
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Tom Krohmer
1/5/11 07:48 AM
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Simplify this for audio so that "low vision" "disabled"
people can participate. Presently, I am getting jerked
all over the CDC phone system, attempting to log on to
this and I do find this a violation of the Americans
with Disabilities Act. "Rosalyn" of whom answers the
CDC phone at (800) 232-4636 says, "We only provide general
information for the CDC, as a private company".
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Linda Karr
1/5/11 12:53 PM
[jump to parent] in reply to Tom K.
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I may need to use audio because by the time of the next conversation I may be low vision
I may need to use audio because by the time of the next conversation I may be low vision
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Facilitator Gail Bingham
1/5/11 08:12 AM
[jump to parent] in reply to Tom K.
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Accessibility
Thank you for letting us know you are having problems, Tom. A technical support person will be contacting you by email. It's a private communication, so if you'd be willing to share your phone number with that individual when he or she contacts you, s/he can assist you in making the audio work for you. It's my understanding that this is part of the system. You can also click my name and then "contact me" and I'll get a private email from you that I can respond to. Gail
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Suzie Campbell
1/5/11 08:48 AM
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Trichlor (trichloro-s-triazinetrione) contains cyanuric acid which ties up with chlorine and extends the kill time for disinfection. How to declare Trichlor is unsuitable to be used as sanitizer for indoor pools and spas?
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David Dorch
1/5/11 09:18 AM
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Why have there not been more laws concerning the testing old dump sites left in place. Many of these dump site are in communities and drinking water supplying the communities. The laws should make mandatoring that all
old dump sites be tested annually, because many chemicals and hazardous waste have been dumped in these old dump site. The dump sites are unlined.
In my community the old dumpsite was use to dump hospital waste and nuclear waste, chemicals,pestisides,leaded paint, and chemical companies waste etc. Anything that they could dumped in the dump site was dumped there. Now there are many people sick in the community.This dump site is over sixty years old. We have to make companies responsible for their action. The environmental agencies of the states and country must do their job in protecting the health and welfare of each person,and protect the wildlife and the environment.
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Active Panelist Lin Kaatz Chary
1/5/11 09:42 AM
[jump to parent] in reply to David D.
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RCRA, TSCA and old dumps
I agree with you completely and appreciate your raising this issue. As it happens, however, I believe that RCRA is the legislation under which these concerns would fall, and TSCA doesn't really have any authority here. It's an excellent example of the fragmentation of regulatory approach that often undermines communities' ability to get action on legacy sites and chemicals. The closest remedy I can think of, imperfect as it is, is the Superfund program - has your site been scored by EPA or your state agency? I hope you are also checking out the other threads in the dialogue dealing with community issues, etc. What kind of laws would you like to see? How would you incorporate this concern into the recommendations that have been made thus far?
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Inactive Panelist Brenda Afzal
1/5/11 11:31 AM
[jump to parent] in reply to Lin K.
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RCRA definition and web resource
For anyone who may not be familiar with the acronym RCRA, it stands for Resource Conservation and Recover Act. The Resource Conservation and Recovery Act (RCRA) gives EPA the authority to control hazardous waste from the "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also set forth a framework for the management of non-hazardous solid wastes. The 1986 amendments to RCRA enabled EPA to address environmental problems that could result from underground tanks storing petroleum and other hazardous substances. To learn more go to the attached URL.
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Eugene Blanck
1/5/11 10:58 AM
[jump to parent] in reply to Lin K.
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Stabilization of old dumps
Some program like superfund must be implemented to make sure these old dumps have funding to make them stable in the environment. Stability must be defined not only as stopping chemical migration from the site, but also must include the site stability as the result of tectonic activity, coastal and river erosion, etc. Old dump sites lacking stability increase costs exponentially when they are not stable. Whatever funding mechanism is used, (e.g., Superfund), chemical and geologic setting site stability must be a key factor in site prioritization.
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Claire Barnett
1/5/11 09:28 AM
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In addition to TSCA reform, near term improvements in preventing harmful exposures can be established. Federal and state environment and health agencies should rapidly expand federal, state, and local agency and K-12 school green procurement programs that will drive out highly toxic materials and provide ready markets for healthier greener products. Importantly, 'green' should be carefully defined as healthy for the environment and human health over the full life cycle of the product, and verified or certified as such.
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Active Panelist Julie Fishman
1/5/11 12:03 PM
[jump to parent] in reply to Claire B.
0 AGREED PANELIST RESPONSE NEEDED RESOLUTION NEEDED 0 REPORTED Executive Order: FEDERAL LEADERSHIP IN ENVIRONMENTAL, ENERGY, AND ECONOMIC PERFORMANCE (PDF)
GSA: Strategically Sustainable (URL)
Video: New GSA Sustainability Plan (URL)
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Green procurement
This is an important strategy that many types of organizations can implement now. The Federal Government has had greening/sustainability requirements of various types for the past 10 years including this most recent Executive Order, attached.

In addition, the head of the General Services Administration (which oversees all federal government procurement) has made sustainability a priority. Check out the attached URLs for a GSA Video on New Sustainability plan for zero footprint and its own plan for becoming a sustainable organization.
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Water Safety 6 Replies New
Hazel Ito
1/5/11 10:51 AM
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I would like to see greater prevention of chemical exposure via our waterways.

I was shocked and dismayed to learn that my home city, along with many others, were recently highlighted in a report by the Environmental Working Group as having high levels of the "Erin Brockovich" chemical, a.k.a. Chromium-6.

While I applaud the EPA for responding and starting to look at levels and decide whether they need to set a safe limit on exposure to this chemical, it really should have been prevented before it even reached this level. It should not be up to a watchdog group to blow the whistle! The EPA needs to shift their focus to preventing these situations, not reacting to them.

I checked out the website of our local Board of Water Supply, and they have a response to the report, and say that they are doing all that the EPA require, etc. but to be honest, that is not very reassuring. It is like they flip the bird at consumers and say in a smug tone, "We are doing all that is required of us." Yes, legally required, but morally - no, you are failing dismally!

Why do we have to wait on an EPA directive to finally filter down to state authorities? Will it even be adequate, given that the EPA has basically suggested that exposure to Chromium-6 might cause "dermatitis" (oh really? how about cancer and death?) Why is it left up to consumers to protect themselves and research and purchase expensive water filter systems or continue to be exposed while we wait on a decision and whatever changes flow on from there?

The EPA should issue a directive immediately that the water suppliers filter out this Chromium-6 and prevent our exposure to this harmful chemical right now! It should not be up to those with knowledge or money to ensure their own water is safe and to hell with the rest of the population. ALL tap water should be safe in this country.
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Geri Aird
1/5/11 03:43 PM
[jump to parent] in reply to Hazel I.
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ALL tap water should be safe in this country.
All tap water should be safe in this country, whether coming out of a municipal water system or a private water system.

For years, my family used a rural private well system with a chlorinator, sand filter and charcoal filter. The water passed the county health department test for coliform bacteria.
I don't recall they tested for anything else.

Recently, the town installed a municipal water system. The county health department has found natural gas in one of the proposed wells for the system, "medium-high" level of radium-226, and medium-high levels of other chemicals.

The town will have to build a $700,000 water treatment plant to remove natural gas, if that water is to be added to the existing supply.

Will it also remove or lower the radium-226?

I wonder what was in the water we drank for so many years.

At least, give rural residents better health department water testing and government assistance, if necessary, to assure they also have safe tap water without risky contaminants.

At most, give people jobs to build municipal systems in cities, towns and countryside, that provide really safe drinking water.

MAKE SAFE DRINKING WATER FOR ALL A TOP PRIORITY FOR PUBLIC HEALTH!




was never advised of People in rural areas are not advised of the various harmful chemicals that are in their water. Health departments do not test for much beyond bacteria count.
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Jennifer McKinnis
1/5/11 11:45 AM
[jump to parent] in reply to Hazel I.
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Choliforms only
I agree. Recently one of my states legislators implemented a water "reclaim project". To participate in the stimulus program. It took waste water from the city treatment plant and piped it into one of the irrigation district's mainlines. This reclaim water was currently being treated for a small number of choliforms (bad bacteria) and then dumped into the river or on one tightly controlled farm. The new program would treat for a few additional bacteria... But that was it.

the waste water, including PVC run off, industrial solvents, pesticides, pharmaceutical (including levels high enough that they'd been sited in another one of those environmental watch reports), including meth by products, would be mixed with the regular ditch water in the mainline and piped to all the farms on the ditch, including those that claimed "organic status."

When I was alerted to this, I began an investigation that contacted every agency involved. Sure enough, it was true. In fact, many cities on the same river, not only get their water from the river, but return their waste water there with no more treatment than for minimal choliforms! They all said, "it meets the legal standard."

Most of the chemical contaminants are known carcinogens, endocrin disruptive and genetically damaging. The chemical they use to kill the choliforms, is a kown neuro-toxin... I'd like to see all treatment plants filter for chemical contaminants, not just bacteria.
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Hazel Ito
1/5/11 01:32 PM
[jump to parent] in reply to Jennifer M.
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Water Treatment Plants Should Filter for Chemical Contaminants
Thanks so much for your helpful comments, Jennifer. I am in 100% agreement with you.

It's great to know people like you are looking into this kind of thing and investigating. This whole fallback of meeting legal standards is appalling, but it shows we need to do a whole lot more on those standards.
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Active Panelist Gail Shibley
1/5/11 11:22 AM
[jump to parent] in reply to Hazel I.
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water & chems
good morning, hazel, and many thanks for your comment. i really appreciate your emphasis on water as an "exposure pathway." there has been a lot of discussion about changing the federal law tsca (toxic substances control act) in the conversation so far, but very little re safe drinking water act (sdwa) or federal food/drug/cosmetic act -- even though food and water are often recognized as leading pathways of exposure.

sdwa allows states to 1) regulate more contaminants than those sdwa covers; and 2) set more (but not less) health-protective standards for those contaminants that sdwa does regulate. i'm not familiar w/ hawai'i law, but you may wish to contact your state drinking water program to see if state-level action is an option for you -- it is in most states.

currently, sdwa regulates 91 contaminants (including 'total chromium,' that includes all types of chromium, not only chrom-6)-- amid many tens of thousands of possible contaminants. thus, attempting to regulate one contaminant at a time just can't cut it. how can/should government at either the federal or state level get away from focusing on the 'contaminant of the month' and more efficiently and effectively protect the public's health?
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Facilitator Gail Bingham
1/5/11 01:35 PM
[jump to parent] in reply to Gail S.
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regulating contaminants as groups
EPA's Administrator Lisa Jackson has called for regulating contaminants as groups. See the attached URL for the EPA's website, Drinking Water Strategy. What do folks think about the approach?
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Hazel Ito
1/5/11 12:55 PM
[jump to parent] in reply to Gail S.
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Water Safety
Aloha Gail,

Thank you for taking the time for your thoughtful reply.

In response to your final question about how government can more efficiently and effectively protect our health, without merely focusing on "contaminant of the month"....well, this requires a massive, massive shift, in my opinion.

Nothing less than a review and change of our entire agricultural system (and industry generally). It sounds like a gross over-simplification (and impossibility) to say we should avoid the contaminants entering our water streams and soil in the first place, but of course that is the obvious answer, and we really need to move more in this direction. Sustainable, organic agriculture, and looking at the entire cost of what we produce, factoring in a "green cost", one that must be paid NOW, and not just one that is anticipated to be paid off by future generations.

I am heartened to see that "green chemistry" is being taught these days. I just wish we could get the same approach and mindset across to those already in the various industries that pollute our waterways and soil.

I see that you have an interest in building confidence in the government. For me, I would have a lot more confidence in the government if the revolving door between large corporations with vested interests and government bodies such as the EPA, FDA and USDA was permanently sealed. I am not sure how this can be done, but I have very little confidence that these groups are genuinely representing MY interests, as opposed to the interests of corporations they have represented in the past, and may well represent in the future... Perhaps they need to be disbanded and something new put in their place.

Mahalo and thank you for listening!
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MARK RUSSELL
1/5/11 12:23 PM
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“The U.S. Chemical output is $400 billion a Year”. “The top 11 of the 100 chemicals in 2000 were Sulfuric Acid (44 million tons), Nitrogen (34), Ethylene (28), Oxygen (27), Lime (22), Ammonia (17), Propylene (16), Polyethylene (15), Chlorine (13), Phosphoric Acid (13) and Diammonium Phosphates (12)”. Over 50% of our Sulfur goes into Fertilizers and the remainder into Batteries, Matches, & Etc. Every Country has a Problem with Chemicals and how to dispose of them and the affects on People, Animals, Trees and the Environment. We can either look at the Glass as ½ Empty or We can Look at the Glass as ½ Full. If we Commit to make our Chemical Industry the Safest in the World that would Yield us the By-product of a New American Industry that would have Global Sales and Millions of New Jobs.

My Background for (25) Years has been in the Recycling and Refining Scrap Metals and Plastics. My Family has been in Recycling for (4)Generations. In one of our Scrap Metals/Plastics Refineries we had our own Water Purification Plant so that no water left our Facilities—That stopped needless Environmental Law Suits. In our L.A. Plant We Prescreened every one of our Workers for all Metal Poisonings----Like Lead and Cadmium. We found that by truly Caring we made nothing but Money in the Subset Profit Centers. We didn’t Pollute the Water System with our Scrap and Chemical Residues because no Water could leave our Refineries and We thereby were able to Capture the Copper Residues in our Water. On today’s Copper Market of $4.40 per Pound that equaled a very Large Profit. We had 5,000 gallon underground Water Storage Tanks for our Ground Water---No Water left our Factory Floors and that Stopped Potential Law Suits from Our Neighbors and Contamination of the Water Systems. We used our Own Purified Ground Water to Irrigate our Trees on our Own Grounds. We Washed our Employee Uniforms in Special Laundries so that we did not Pollute the Water System with Potential Metals, Chemicals and Toxins. We required Everyone of our Workers to Shower before they went home to take all Dust and Dirt off their Bodies. We Monitored our Workers every (4) months for Metal & Chemical Poisoning. We Monitored the Air and the Water Around our Factories.

Could you image a New Industries for the United States

· Stopping the Chemical Pollution/Exposures and Creating a Giant
Profit Center for Industry and to Pay Off Our National Debt with
Billions in Profits Yearly.

Many years ago Sulfur was a Giant Problem to most every Major Copper, Oil, and Steel Company and today Sulfur is a Profit Center. By Caring you can make Incredible Profits. By Caring about CO2 Pollution We can Create a New Industry based in the US with Millions of New US Jobs. We can Come up with Great Ways to Recycle the Used C02 from the Power Coal Power Plants like---- “Kelp Farming”, “Underground Oil Production”, “Soda Pop”, & Etc. Before the General Public got involved in Recycling it was the 10th largest Industry in the US.

One of our biggest problems is our Chemicals that we Consume and Make Is:

· How do we Make Them?
· How do we Transport them?
· How do we Use Them?
· How do we Dispose of Them?

Every one of these Subsets is a Possible Problem in our Equation and a New Business for the US. There is an old Biblical saying---“Before you take the spec out of my Eye--Take the Log Out of Your Own. My Experience in Recycling and Every Recycler that I have ever known---They all say that -----We made a Giant Profits when we were Required to Clean up our Waste Streams. Chemicals goes into the Ground Water Tables like In our Cattle Feed Lots Cow Dong or Nitrous Oxide. One of our Biggest Superfund Hazardous Waste Sites in the US is the Cattle Feed Lots. I know a Man that worked for Kellogg Fertilizer Company and they converted the Sewage Waste from the City of Los Angeles into Fertilizers.

· The problem is not our Foreign Enemies---It’s Ourselves.
· The Biggest Problem We have is Our Already Existing Chemical
Pollutants
· The Biggest Solutions is to Practice Preventative Medicine with
Chemicals
· How many Lives would we save in the US this Year if we Reduced Our
Chemical Pollution by 50%?
· How many Billions could we make if we Recycled 50% of the
Chemicals from our Cars, Buses, Trains, Factories, and Sewage
Treatment Facilities?

In 1898 Cancer became a Science and at that same time only 2-5% of all Cancers were Cureable. Today over 95% of all Cancers are Cureable if you catch them at Stage (1 or 2). The Same holds True for Chemicals if we use a Preventable Medicine Approach.

· “Most Engines Retain an Average Efficiency of about 18%-20%”
· How can we make a Car Engine 200% more Energy Efficent and Reduce
Pollution by 200%?
· How many Jobs would we create by making a car 200% more Energy
Efficent?

Most people today speak about Polyethene Bags and the Problems to the World and No One says that


“Give a Man a He’ll Starve---Teach a Man to Fish He’ll Live a Lifetime”


We are the Problem and We are the Solution.

Millions of Jobs could be Created and Billions of Dollars in Profits Made by Cleaning up Our Chemical Waste Streams. Millions of Lives could be saved from Cancer and Other Auto Immune Diseases by Caring. Besides all of that we could Position the United States to be a Leader in:

· Building Safe Chemical Factories in the US and Worldwide
· Transporting Chemicals Safely to Reduce 500% of the Potential
Threat
· Building Chemical Recycling Equipment to Produce Billions in
Potential Profits Yearly.
· Engineer a Gas Engine to be 60% Energy Efficient rather then “18-
20% Energy Efficient”--Thereby Reducing our Air Born Chemical
Toxins by Potentially 300%.



M. Russell
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Facilitator Gail Bingham
1/5/11 02:56 PM
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The facilitator is signing off with thanks to everyone for your participation. Registration topped 500 today! Please feel free to continue the dialogue this evening, if you wish, and come back tomorrow to discuss chapters 2, 3 and 7 of the Action Agenda. Warm regards, Gail
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carolyn gorman
1/5/11 03:09 PM
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Air exchanges are not increased as designed by law when construction or renovation is performed in the workplace. Air quality is not sufficiently monitored. This results in chemical exposure to employees. Green or less toxic products are not always used. Employees are not given information as to the chemicals being used in the renovation.

Lack of information and protection causes loss time for industry and lost wages by those made ill.
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Barbara Warren
1/6/11 09:29 AM
[jump to parent] in reply to carolyn g.
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recommendation 3.7 addresses research on Indoor Air pollutants
In addition to research we really need to develop sound best practices for building managers and increase the outreach and education around implementing healthy indoor air quality
programs. We need to better use what we already know.

Such programs should address: renovations likely to pose air quality issues, steps that can be taken when making purchasing decisions, timing of renovation (off hours) and need for increased ventilation.
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ricky choy
1/5/11 05:46 PM
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Allow us to propose that new laws be enacted & given incentives to give more emphasis to product research & development of new products to replace existing products found to be toxic to man, animals & plants. No amount of product disclosures or labeling will prevent the misuse of toxic chemicals unless it is replaced or pulled out from the market.
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Nancy Swan
1/5/11 06:55 PM
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The recommendations in Chapter 1 of the Draft For Public Comment suggest prevention of chemical exposure to children and vulnerable populations, however, there is no mention of prevention of chemical exposure to children and personnel at schools. As a Community Conversation leader, my participants were stunned, then outraged that there is no agency to oversee toxic and hazardous substances used to clean, in pest control, and in renovation and construction. The hundreds of stories about chemical exposure and injuries in US schools are posted on my website and are proof that the need for specific wording in the National Conversation to protect school children and personnel.Resource: http://www.nancyswan.com/interes...
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Inactive Panelist John McLeod
1/6/11 08:48 AM
[jump to parent] in reply to Nancy S.
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Prevention of chemical exposure at schools
Nancy, Thanks for your comments. We mentioned this very issue in our dialogue yesterday. More specifically, the need for a sustainable chemical management system for school districts, which encompasses purchasing, storage, application and removal processes. The USEPA SC3 initiative and tools for schools encourges this kind of management processes that many schools have embraced. The development of chemical management systems in schools, institution and industry has been a recommendation from our policy and practices workgroup.
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Nancy Swan
1/5/11 06:55 PM
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The recommendations in Chapter 1 of the Draft For Public Comment suggest prevention of chemical exposure to children and vulnerable populations, however, there is no mention of prevention of chemical exposure to children and personnel at schools. As a Community Conversation leader, my participants were stunned, then outraged that there is no agency to oversee toxic and hazardous substances used to clean, in pest control, and in renovation and construction. The hundreds of stories about chemical exposure and injuries in US schools are posted on my website and are proof that the need for specific wording in the National Conversation to protect school children and personnel.Resource: http://www.nancyswan.com/interes...
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Nancy Swan
1/5/11 07:39 PM
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The wording of recommendations in Chapter 1 imply that the chemical industry will continue to control its reporting and monitoring statistics and voluntarily comply.

I see little hope and even less specific wording that any or all of these recommendations would have prevented the serious and permanent chemical injuries I suffered while teaching at a public school in Mississippi in 1985. Over a thousand children and teachers were exposed to some of the most toxic chemicals manufactured during application of a foam roof containing isocyanate, benzene, and toluene. The chemicals were stored on school property in tankers and chemical drums w/o security for over two weeks. The injured and exposed were denied chemical information. We were shocked to discover that no local, state, nor federal agency had authorization for oversight nor enforcement of existing regulations. For occupants of schools, nothing has changed in more than 25 years. http://www.toxicjustice.com

Where is the oversight in industry and workplace compliance, effective enforcement and accountability for failure to comply? How and will oversight, enforcement, and accountability be funded? Many of our well intended and well worded government regulations fail because there is little if any provision for oversight and no effective accountability to protect the public from chemical exposure and injury.

Perhaps a test application of these recommendations would be helpful. How would these recommendation have prevented my chemical exposure and injury and that of the more than two dozen children who were seriously injured?
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Elizabeth O'Nan
1/6/11 10:25 AM
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RESOLUTION TO ESTABLISH A
TOXIC TORT ABATEMENT ACT
WHEREAS, pesticides, nuclear waste, hazardous waste, PVC, and other dangerous toxic chemicals inevitably injure, disable and kill innumerable citizens each year, and
WHEREAS, citizens are not finding just compensation in the courts for these injuries due to; fraudulent concealment of the harmful effects of chemicals, manipulation of research data, falsification of data by test labs, conflicts of interest on scientific research panels, corporate 'disinformation' and corporate political donations, failure to enforce protective laws and regulations, and
WHEREAS, studies indicate from 15-30 % of the population experiences some form of chemical intolerance, with around 3% of these being seriously disabled, and
WHEREAS,  chemical induced injury is linked to chronic and deadly diseases such as Cancer, Toxicant Induced Loss of Tolerance (TILT), Parkinson’s and Alzheimer’s Disease, Diabetes, Heart Disease, Attention Deficit Disorder (ADD), Chronic Fatigue Syndrome, Fibromyalgia, endocrine, neurological and immunological damage, aggression, , loss of bone density, and other chemical injuries, and
WHEREAS, tax dollars, in the form of Medicare and Medicaid, generally provide coverage for health care when citizens are chemically injured or disabled and are unable to receive fair compensation in the courts or maintain their financial independence, and
WHEREAS, research into causes, treatments, and cures of chemical injury is inadequate due to limits on funding controlled by compromised elected representatives dominated by the self-interest of corporations, and
WHEREAS, no provision is made for the many special needs of chemically injured and disabled citizens such as; emergency and long-term medical care and housing, legal representation,  schooling, personal products and household goods, communication and socialization.
THEREFORE BE IT RESOLVED, that this Toxic Tort Abatement Act shall reduce litigation through fair treatment of the chemically injured and disabled and reducing feelings of frustration, anger and betrayal.  We recognize the moral responsibility to eliminate the use of toxic chemicals which cause injury, disability and premature death to a significant percentage of citizens.  Until harmful chemicals are eliminated those who profit from toxic or harmful products, chemicals, hazardous waste, and radiation must provide for the needs of inevitable victims.
THEREFORE BE IT RESOLVED, that any and all corporations that manufacture, process, dispose of, or incorporate into other products any toxic chemical or hazardous products that would cause chemical injury, disability or death, will contribute 2% of the corporations gross annual income to the Toxic Tort Abatement Fund to be set aside for the needs and expenses of chemical injury survivors and their families.  This Act presupposes that compassion, fair treatment, and sincere apology reduce the need and will to litigate.  Corporations may best show compassion, fair treatment, and sincere apology by providing in advance for those who are inevitably injured, disabled or killed.
This Act in no way limits or prohibits the right to file, pursue or recover in any toxic tort lawsuit. 
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