This week I discuss with my colleague, Dr. Richard E. Engler, Director of Chemistry for B&C and The Acta Group, our consulting affiliate, the importance of engaging early and often with the U.S. Environmental Protection Agency (EPA) in the Toxic Substances Control Act (TSCA) Section 6 risk evaluation process. We discuss conditions of use (COU) of a chemical being evaluated by EPA, the reasons why educating EPA on COUs is critically important to regulated businesses, the relevance of ECELs, existing chemical exposure limits, and the consequences of a Significant New Use Rule (SNUR) for use conditions out of scope of a risk evaluation. We also discuss EPA’s evolving thinking regarding ECELs and why EPA’s thinking is a hot topic of discussion.
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