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SciPoll 551: USEPA's Proposed Changes to TSCA Risk Evaluation Framework Rule
The scope for a "chemical substance" should be extended to also apply to a "category of chemical substances"
Results
(110 Answers)
Answer Explanations
- Agreeuser-691039Get in line with REACH
- Agreeuser-655473Recently more than 2.5 billion tonnes of synthetic chemicals are produced globally. >25% are petroleum compounds, >26% are speciality chemicals, and >19% are polymers (https://cefic.org/a-pillar-of-the-european-economy/; approximately 300 kg per year for every man, woman, and child in the world). Also agrichemicals are the most dangerous in the world. China, EU and NAFTA remaining the largest consumers of that chemicals and aim to increase trade or use of chemicals (excluding pharmaceuticals) by 70% till 2030.
So, "category of chemical substances" is better to better understanding risk-based policy implementations for the assessment of all chemicals and mixtures. In addition, extending that scope can help to better implementing mandates of UNEA3 concerning the chemical pollution to achieve the sustainable development goals (SDGs) with the collaboration of FAO, WHO and Global Soil Partnership (GSP). - Agreeuser-411596Extending the scope to apply to a category of chemical substances can enhance regulatory efficiency and provide a more comprehensive approach to risk management. However, careful consideration must be given to definitions, data requirements, and potential challenges to ensure that the regulatory framework is effective and practical for both regulators and industries.
- Disagreeuser-414626To regulate by category was a mistake made by the EU with the PFASs. Chain length has a strong influence on TK and TD and you might end up with the throwing the baby out with the bathwater!
- Agreeuser-573537Using a broader scope would allow for the inclusion of current non-existant molecules.
- Agreeuser-98823Often times, a chemical with toxicological concerns is regulated, but a closely related chemical which might be predicted to have toxicological impacts remains unregulated simply because it is not identical to the parent substance. The lack of regulation is not based on data, but rather on "non-identity".
- Agreeuser-378118There are so many types of Chemical substances, each of them with potential significant differences, that making more specific evaluations would have merits. Better than using imprecise tools to define risks.
- Disagreeuser-521436Chemical categories sound good, but in fact not every chemical in a "category" has the same effects as other chemicals in the same "category" so they need to be assessed as independent chemicals.
- Agreeuser-574398Given the scarcity of data on many individual chemicals, a class-based approach can provide some indication of toxicity for data-poor chemicals.
- Agreeuser-998255It's more efficient, especially for complex substances
- Agreeuser-653570chemical families with similar structures are often grouped
- Agreeuser-673903"Category" can cover more chemicals through the use of read across or QSAR and perhaps decrease time and money for risk assessment. More efficient than one chemical at a time.
- Agreeuser-208008It is more comprehensive for novel chemicals.
- No opinionuser-931808Don't believe it needs changing
- Agreeuser-754769The definition of chemicals in recent years should be expanded. It is undesirable for the general public that some substances fall through the gaps in the law due to the creation of new chemicals as a result of scientific progress.
- Agreeuser-553839If we deal with chemical, it is more appropriate and useful to have its category. This information will help decide future course of action related to this chemical. This becomes particulalry important if the chemical happens to be hazardous one. Chemistry is important but safe chemistry guarantee our safe future.
l - Agreeuser-678105Some chemical substances within a category may also present risks but have not yet been adequately evaluated.
- Agreeuser-997228Expanding the scope of regulations from a single "chemical substance" to cover a broader "chemical substance category" can present several potential benefits and challenges.
- Categorizing chemicals can streamline regulatory processes by addressing entire groups of substances with similar characteristics or properties, reducing the need for separate evaluations for each chemical.
- Assessing categories of chemical substances allows for a more comprehensive understanding of risks associated with similar compounds. This approach can expedite risk evaluations and facilitate more efficient risk management strategies.
- Disagreeuser-153764the identification of a specific chemical by CAS number is intended to eliminate confusion. If one were to identify constituents of concern by category (e.g. glycol ethers) materials that have high toxicological activity would be lumped together with those that show no such activity
- Agreeuser-568782Categorization is important for classification purpose. Based on property similarity or identity a "chemical substance" should be extended to apply to a "category of chemical substances".
- Disagreeuser-445218Many chemicals within a category of chemical substances could, and often do, have significantly different risk profiles. Between splitting versus lumping I vote for keeping it split.
- Agreeuser-378617yes the EPA should be able to regulate chemicals as a class/group.
- Agreeuser-911600Saved time and effort
- Agreeuser-523578New chemical substances are being developed all the time. It's impractical to add them as we go. What matters is the effect and the danger they pose.
- DisagreeSciPinion Adminthis is a practice for which IARC was chastised: one should be encouraged to be as specific as possible because "categories" (defined as???) of chemicals can have very different toxicities, e.g. various forms of arsenic.
- Agreeuser-774962The discipline of SAR and QSAR is advancing at a rapid pace. If for example, a specific chemical structure is shown to have (or not have) the activity of concern, the biological activity of that structure, with the limitations imposed by knowledge of the substance's mechanism, should be implied for other structures in that category.
- AgreeSonne72Depends on def of chemical substance.
- Disagreeuser-841110Not clear how "category" will be used. Relatively minor changes to a chemical, e.g. additional of an alkyl group can great affect its bioavailability and toxicity. Unless there is clear scientific evidence that a group of similar compounds have similar toxicity, the focus should still be on individual chemicals.
- Agreeuser-125195To improve efficiency and throughput
- Agreeuser-153519I would advise putting both terms: "known chemical substance" and "category of chemical substance." The problem with writing only chemical substances is that unknown substances would not be considered.