So back to the original question: Why would ACMA support the legislation? Consider this:
- Styrene is already on the priority list for a TSCA assessment, and the EPA has promised to issue a styrene safety standard under its current program by 2018.
- Styrene will also be subject to a risk assessment and issuance of a safety standard under the EPA Office of Air’s MACT Risk and Technology Review program.
- Styrene is on the priority list for issuance of updated workplace exposure limits by both Federal and California OSHA.
- The first of these programs to get to styrene will likely have a very significant influence on subsequent risk assessments.
- CS-21 would, for the first time, legislatively mandate science quality measures, and a reformed TSCA would be under close scrutiny by stakeholders and Congress.
Under a reformed TSCA, the EPA would have to conduct a very transparent assessment using published guidelines and employ a weight-of-evidence approach to hazard assessment. By no means do these legislative requirements guarantee a valid styrene assessment, but they make it much more likely styrene will receive a scientifically valid toxicity review under a reformed TSCA than under any of the other regulatory programs interested in this substance.
Working against science quality will be the aggressive deadlines set by CS-21 for issuance of safety standards. The Act’s sponsors expect the EPA’s reformed TSCA program to conduct safety assessments and issue risk management requirements for 25 chemicals a year, once the program is fully implemented. Consider that the EPA’s IRIS program did not complete a risk assessment for even one substance during all of 2014.
Getting valid safety assessments out of a reformed TSCA program – so the composites industry is allowed to continue using styrene – will require aggressive and continuing attention by ACMA and other stakeholders and effective Congressional oversight. But the industry still has better odds here than under any of the other options.
