I also went through the outrageous CSA powerpoint discussed on the webinar. And while my major issue with the law is the piddling number of chemicals that will actually be tested and that they are the wrong chemicals and the wrong tests, I'd like to just look at one of those CSA webinar slides, The one that said:

Someone should have asked what the provisions of the 5(e) and 5(f) orders are. Essentially, they are the same review procedure that has always been in place for PMN and SNURs that EPA has been using unsuccessfully for decades.  They still are asking EPA to determine risk in the absence of data.  And industry can still hold up the action by claiming that EPA did an unfair risk assessment.

I'm sure you know, but maybe others on the list re not familiar with these. Since 5(f) supposedly allows EPA ban production and to get a court injunction to stop manufacture (don't wait to see this happen), it make more sense to look at 5(e):

NOW answer these questions:

1.  Did you see any testing requirement to find out what the stuff ACTUALLY does to the worker or other people?   Or is it still based on a risk assessment by analogy and without REAL data?

2.  Did you see any requirements for hazcom other than for the workers manufacturing the chemical?  Are workers using this chemical downstream included here?

-----Original Message-----
From: Roger McClellan <roger.o.mcclellan**At_Symbol_Here**ATT.NET>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Fri, Jul 1, 2016 6:03 am
Subject: Re: [DCHAS-L] Today's Overview Webinar on New TSCA

To all:
This bill has been moving through the system for years and with passage by the Congress and signature by the President it is the law of the line.. I would be shocked if any substantive amendments will be made to the legislation in the next decade. Yes, there may be some minor clean up of legislative language next year as is customary for major legislation. However, I doubt the Congress will have any "stomach" for re-opening the legislation for major changes. The opportunity for addressing perceived short comings is now history.
This legislation as always has some latitude as to how it is implemented. Thus, I urge interested parties to closely follow the actions of EPA, especially over the next 1 to 2 years, as it implements the legislation. This is always challenging and time consuming. However, occasionally specific targeted efforts by interested persons and parties can influence EPA's actions on the first chemicals addressed which in turn can set the precedent for actions on future reviews on other chemicals.
It is my personal opinion that the legislation contains a lot of language, for example, frequent use of the phrase-- "unreasonable risk", that gives the EPA broad policy discretion in taking or not taking certain actions on specific chemicals. Finally, I would note my own personal view from following EPAs actions since its origins --- "Science needs to inform policy judgements and regulatory actions, however, science alone is not sufficient for dictating specific policy outcomes." It is important for scientists to make certain EPA gets the science right. If a scientist or group of scientists have difficulty with a particular agency decision it is important to critically examine the matter and determine whether the problem is with the science or the policy decisions leading to a particular regulatory outcome..
It is going to be interesting to follow the EPAs actions over the next several years. One thing the legislation does do is set some specific goals and time lines for the Agency to attempt to meet in the future. This is a clear response to the slow progress made by the EPA in moving chemicals through IRIS review over the last several decades.
Over past decades much time and energy has been expended in debating the relevance and role of data from laboratory animal studies in assessing human hazards and risks. Increasingly, attention will shift to interpreting the results of studies with experimental systems that do not use animals. The debate over emphasis on hazard characterization versus quantitative risk assessment will also continue. The recent debate over actions of IARC is a preview of what to expect. As an aside, did you note that IARC changed its classification of coffee consumption -its cancer hazard is no longer established. However, be careful what you drink, hot water is now on the IARC list of possible human carcinogens.
It is a wild, wild world at the interface between science and policy. I urge everyone to become engaged in the process, but, try to distinguish between whether your arguments are with how the science was used or with your own preference for a different policy outcome.
Regards to all.
Roger

Roger O. McClellan, DVM, MMS, DSc(Honorary)
Diplomate - ABVT and ABT; Fellow -ATS, SRA ,HPS, AAAR and AAAS
Member - National Academy of Medicine
Advisor, Toxicology and Human Health Risk Assessment
Albuquerque, NM 87111

--------------------------------------------
On Thu, 6/30/16, Alvaldenio**At_Symbol_Here**verizon.net <alvaldenio**At_Symbol_Here**VERIZON..NET> wrote:

Subject: Re: [DCHAS-L] Today's Overview Webinar on New TSCA
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Date: Thursday, June 30, 2016, 5:19 PM

Ralph,  In view of the
many shortcomings of the new law, should our Division start
proposing a series of amendments for the next session of
Congress?  Al Denio

Sent
from my iPad

> On Jun 30, 2016, at
6:23 PM, Secretary, ACS Division of Chemical Health and
Safety <secretary**At_Symbol_Here**DCHAS.ORG>
wrote:
>
> Note that
the slides from today's webinar are available at:
> https://urldefense.proofpoint.com/v2/url?u=https-3A__www.epa.gov_sites_production_files_2016-2D06_documents_june-5F30-5Fwebinar-5Fppt.pdf&d=DQIFaQ&c=lb62iw4YL4RFalcE2hQUQealT9-RXrryqt9KZX2qu2s&r=meWM1Buqv4IQ27AlK1OJRjcQl09S1Zta6YXKalY_Io0&m=U9vNbObAZcOW-J-qlR_zGLWOdaaGwrkOk0gi7wpP0T4&s=umayrGDMb8zbEq3RH7GE0MzaTJLRQ52FSgvCt_1IQV0&e=

>
> - Ralph
>
> From: "U.S. EPA
Office of Chemical Safety and Pollution Prevention"
<oppt.epa**At_Symbol_Here**public.govdelivery.com>
>
> Regarding today's
webinar on the new TSCA, our sincere regrets that some
people were not able hear the audio or were not able to join
at the beginning of the presentation. Our conference lines
were overwhelmed by the large number of participants. We
plan to host another overview webinar in the near future.
Information for this future webinar will be sent out through
this Listserv and available at the new TSCA webpage. Please
accept our regrets.