The Toxic Substances Control Act (TSCA) gives EPA the authority to enforce reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures in commerce. Our scientists at Cardno ChemRisk applied our expertise in systematic review, toxicology, and industrial hygiene and exposure characterization to provide several clients with quantitative occupational and consumer use hazard and exposure assessments and regulatory comment support.

Project Example: Exposure Modeling and Regulatory Comment on Four TSCA Risk Evaluations

Project Overview: Cardno ChemRisk critiqued and provided commentary on the draft EPA TSCA risk evaluations for four prioritized chemicals for an industry trade group.

Our Approach: For each chemical, we reviewed the occupational exposure assessment methods for all routes of exposure and provided in-depth commentary and alternative strategies (including alternate data sources, analysis methods, and/or exposure assumptions) that EPA could employ to strengthen the exposure assessments. Our comments were submitted to the Science Advisory Committee on Chemicals and to EPA for consideration in revisions to the draft risk evaluations. We also prepared and presented oral comments to the Scientific Advisory Committee for one of the chemicals. We continue to work with the client to provide support in the risk management phase of the TSCA process.

Our Value: In response to our comments, EPA performed additional statistical analyses of occupational exposure data, and updated risk evaluation discussions in the final risk evaluation.

Project Example: TSCA Occupational Exposure Test Order Support

Overview of Projects: Cardno ChemRisk is providing support to several industry Consortia with responses to the Environmental Protection Agency (EPA) TSCA Section 4 test orders for occupational exposure data. This work is in response to EPA’s request for dermal wipe sampling, dermal absorption data, and inhalation exposure monitoring data for several chemicals prioritized for TSCA risk evaluation.

Our Approach: Cardno ChemRisk is facilitating the identification of similar exposure groups, collection of qualitative information for relevant occupational exposure scenarios, sampling test plan development, communications with EPA, sample collection, and data collation and submittal to EPA.

Our Value: Cardno ChemRisk has helped clients navigate complex TSCA regulatory requirements. Our team has been involved in the analysis and public commentary on all TSCA risk evaluations conducted to date, and has been able to leverage that experience to propose tiered approaches to occupational exposure assessment. Such recommendations have improved the quality of data being collected for occupational exposure assessment under TSCA.