The TSCA New Chemicals Coalition: Why Your Company Should Join

Any company that plans to submit or has pending a new chemical notification under the Toxic Substances Control Act (TSCA) needs to join the TSCA New Chemicals Coalition (TSCA NCC) — the only coalition focused principally on TSCA Section 5 issues. The TSCA NCC has been relentlessly engaging with the U.S. Environmental Protection Agency (EPA), the U.S. Occupational Safety and Health Administration (OSHA), and Congress on identifying and addressing real-world issues arising out of EPA’s implementation of the new TSCA Section 5 provisions.  

By joining forces with other TSCA NCC members, companies gain a unique advantage in that they have a clearer understanding as to whether EPA’s determinations on its chemicals are consistent with other Section 5 determinations.  Through engagement with the TSCA NCC, member companies obtain greater insight into EPA’s approaches than they would alone, and thus are better able to navigate the daunting process of TSCA new chemical review.

Since its inception last year, the TSCA NCC has:

• Met with EPA officials on several occasions to discuss concerns related to protracted review times and diminished transparency in EPA approaches;
• Conducted comprehensive analysis of the basis for and potential approaches to fulfilling mandated consultations between EPA and OSHA prior to EPA’s adoption of new chemicals restrictions to address workplace exposure concerns;
• Conferred with EPA, OSHA, Congressional staff, and other key TSCA stakeholders on OSHA analysis;
• Conferred with senior EPA staff on TSCA NCC proposals that provide practical approaches for EPA findings on workplace exposure issues;  
• Provided regular updates to members related to new chemicals implementation activities, including articles of interest, regulatory developments, and/or blogs from TSCA stakeholders;
• Alerted TSCA NCC members to troubling language included in EPA communications;
• Conferred with EPA leadership on its Points to Consider document for new chemicals notifications;
• Submitted comments on EPA’s new chemicals framework documents;
• Participated in EPA workshops on new TSCA;
• Analyzed premanufacture notification (PMN) determination findings;
• Interacted with other organizations on areas of shared interest related to TSCA new chemicals issues and workplace exposure findings, including the American Industrial Hygiene Association (AIHA) and the Society for Chemical Hazard Communication (SCHC);
• Prepared comments on EPA industry fees proposal, with a specific focus on limiting fees related to new chemicals notifications; and
• Convened multiple conference calls for members to share perspectives and develop advocacy strategies.

Membership in the TSCA NCC is open to chemical and chemical product manufacturers and processors; trade associations may not join.  Annual dues are $1,000 per company. Join our two dozen plus members and get ahead of the TSCA PMN curve.

Contact Lynn L. Bergeson or Kathleen M. Roberts if you are interested in joining or need more information.