ASDWA Provides Support for EPA’s Prioritization Process under TSCA

In comments submitted to EPA on March 14, ASDWA provided support for the Agency’s chemical prioritization process under the Toxic Substances Control Act (TSCA). In a notice published on December 13, EPA announced the initiation of a 12-month process to prioritize five additional toxic chemicals for risk evaluation under TSCA. If the Agency designates these five chemicals as High Priority Substances, EPA will begin risk evaluations.

The notice outlines EPA plans to prioritize the following chemicals:

  • Acetaldehyde (CASRN 75-07-0),
  • Acrylonitrile (CASRN 107-13-1),
  • Benzenamine (CASRN 62-53-3),
  • 4,4’-Methylene bis(2-chloroaniline) (MBOCA) (CASRN 101-14-4), and
  • Vinyl Chloride (CASRN 75-01-4).

ASDWA’s comments supported the action as “a crucial first step in determining if substances’ may present an unreasonable risk of injury to health or the environment because of a potential hazard and a potential route of exposure under the conditions of use.’” The association stressed the importance of sound science and peer-reviewed data to support any future regulatory actions. ASDWA’s letter emphasizes that the process will “help ensure that the Agency’s limited resources are directed to where they are needed most to address the contaminants of greatest public health concern.”

ASDWA provided specific support for the inclusion of vinyl chloride, which is used to produce polyvinyl chloride (PVC) pipe, one of the most commonly used materials distribution system pipes. The current MCL for vinyl chloride is 0.002 mg/L. ASDWA’s comments stressed that EPA “must ensure that vinyl chloride does not leach from these pipes, which would become a significant concern to the public,” emphasizing that reliable, peer-reviewed data is vital to understanding exposure and public health risks.