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May 20, 2021

Richard E. Engler, Ph.D., Quoted in Chemical Watch Article “What would substance-wide TSCA risk determinations and other new approaches mean for stakeholders?”

The ACTA Group

On May 20, 2021, Chemical Watch featured comments by Richard E. Engler, Ph.D., Director of Chemistry, The Acta Group (Acta®) regarding recent policy shifts signaled by the US EPA on how it conducts TSCA risk evaluations.

Incorporating environmental justice considerations “may present a significant analytical challenge if EPA seeks to move beyond a fenceline cumulative exposure approach”, for example, if a worker is exposed at work and then through living near that facility, said Richard Engler, director of chemistry at Bergeson & Campbell.  “It is not clear to me that the data are available to support a more refined analysis.”  

A screening-level tool that the EPA could use is its Risk-Screening Environmental Indicators (RSEI) data, said Dr Engler, a former leader of the EPA’s green chemistry programme. RSEI puts toxics release inventory (TRI) data into a risk context, and could point the agency to potential locations to focus analysis and geography-specific regulations, he said. For example, it could conduct local monitoring and, if necessary, choose to lower permitted releases from clustered facilities to account for cumulative releases.

But the approach would be novel. “As far as I know, EPA has never used the RSEI data in this way,” Dr Engler said. 


The EPA has only one year to propose risk management rules once it identifies an unreasonable risk in a final risk evaluation, and a further year to finalise them.

It is possible that the agency will proceed with rulemakings in instances where it has identified unreasonable risk and supplement those regulations if it identifies additional conditions of use that present an unreasonable risk, said Dr Engler. 


“I suspect it will be some time before we see EPA completely wrap up its risk management actions for any of the first ten,” said Dr Engler.

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