Reforming US Chemicals Policies: The Importance of Implementation and Systems Thinking

Chemicals regulation in the United States is in dire need of repair. Researchers and government bodies have noted the various limitations of the Toxic Substances Control Act. While much of the discussion about TSCA has focused on the limited authorities the Act provides to EPA to gather information and restrict chemicals of concern, this alone cannot explain the limited performance of the Act over the past 30 years. A myriad of statutory, procedural, political, and resource factors together created a situation that inhibited the ability of EPA to effectively collect data and manage chemical hazards. Further, TSCA's limited scope and the artificial jurisdictional boundaries established for management of chemicals in everyday products, toys, workplaces, and food contact and cosmetic products create barriers to effective chemicals management and a focus on safer design. In this presentation, we explore some of the factors that have affected TSCA's implementation, some of they ways EPA has attempted to address barriers to TSCA implementation, and some of challenges of a disjointed system of chemicals management. We propose an approach to comprehensive chemicals policy, a systems based approach to chemicals management with the goal of designing and applying safer chemicals throughout their supply chains.