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R L Keener

Publications and source records attributed to R L Keener.

4 recordsLinked to original sources

Chemical control laws on polymers: A case for harmonization.

All industrial countries, and several emerging and developing countries, have established regulations to control chemical substances, with a view toward limiting the risks to workers and the public, as well as reducing the impact on the environment. However, the lack of harmonization among such international schemes is creating international trade difficulties. In this context, polymers, and particularly specialty polymers, are a unique case. Polymers are less easily characterized than other substances, and parameters used by governments to control them may vary greatly, leading to national regulations that are significantly dissimilar, or even incompatible. This paper reviews chemical control laws on polymers, identifies the major differences between them, and suggests model legislation for polymers that would reduce barriers to international trade in polymers while maintaining a high degree of human and environmental protection.

Economic Competition↗

Regulation of existing chemicals under TSCA: information disclosure as the route to reducing risk and increasing available data.

The Toxic Substances Control Act (TSCA) empowers the Environmental Protection Agency (EPA) to regulate risk associated with the use of existing chemicals and the introduction of new chemicals into commerce. Due to a number of concerns, however, the authority to regulate existing chemicals under TSCA has enjoyed limited success. A more generic and flexible approach is needed to achieve significant risk reduction for existing chemicals. This paper presents a frame-work for a generic approach to the regulation of existing chemicals. Under this framework, EPA would officially recognize that the distribution of chemical substances without evaluating and communicating to the user how to avoid operationally undesirable exposures represents an unreasonable risk to health or the environment. Acting under the authority of TSCA, EPA would then generically require suppliers to communicate acceptable exposure levels and information regarding safe use. This framework is consistent with the express policy of TSCA, which states that development of data with respect to the effects of chemical substances and mixtures on health and the environment should be the responsibility of manufacturers and processors of chemicals. The approach outlined here is consistent with and complements initiatives of the Office of Toxic Substances (OTS) and would enable OTS to accomplish some of the fundamental goals of TSCA.

Chemical Industry↗

Regulating the introduction of new chemicals under section 5 of TSCA: improving the efficiency of the process and reducing potential injury in the workplace through the use of operational MSDS and exposure limits.

The Toxic Substances Control Act (TSCA) authorizes the EPA to take appropriate actions to ensure that new and existing chemicals do not pose "unreasonable risk" to health or the environment. Section 2(b)(3) of the Act directs the Agency to accomplish this objective in a manner that does "not impede unduly or create unnecessary economic barriers to technological innovation." In recent years, critics have felt that the EPA has failed to achieve these primary goals of TSCA. This paper considers some of the reasons for this criticism and advocates an alternate approach of exposure limits and operationally sufficient controls to assist in achieving these goals. An illustration of how this alternate approach might work under practical conditions is presented, using as an example a new chemical substance from the class of acrylate monomers. These concepts and risk assessments provide data for a better design of future studies according to good laboratory practice and quality assurance.

Chemical Industry↗