American Chemistry Council (ACC) testified that, "Unfortunately. . . today we are discussing a bill that remains very similar to the bill introduced in 2010, which we consider unworkable." In his testimony Dooley outlined several fundamental flaws with the bill, including an unachievable safety standard, data requirements that would undermine the success of the current program to evaluate new chemicals, the creation of an overly burdensome and unnecessary minimum date set for all chemicals, and the lack of an effective prioritization process. He said, "We also believe that S.847 would compromise the protection of confidential business information, inappropriately expand the U.S. Environmental Protection Agency's (EPA) authority into the jurisdiction of other federal agencies such as the U.S. Food and Drug Administration (FDA), further complicate issues surrounding national uniformity of standards, and fail to adequately consider animal welfare."
Environmental Defense Fund (EDF) on behalf of the Safer Chemicals, Healthy Families, a coalition of over 300 organizations that speak for more than 11 million Americans. The coalition includes groups representing health professionals and health-affected populations and communities, environmental justice organizations, leading businesses, and state and national environmental groups -- all of whom came together to urge Congress to fundamentally reform the Toxic Substances Control Act of 1976. After outlining a series of problems with TSCA, EDF said, "All of these problems would be largely or entirely ameliorated by adoption of legislation introduced this year, S.847, the Safe Chemicals Act of 2011. It provides the framework for a comprehensive, systematic solution to a set of problems that until now have only been addressed -- if at all -- through reactive, piecemeal actions.EDF said, "We have ongoing dialogues with the American Chemistry Council (ACC) and the Consumer Specialty Products Association (CSPA) and more than a dozen of their member companies; these have involved many days of substantive meetings on key issues in TSCA reform over the past six months. . . While confidentiality agreements preclude me from discussing details, let me say that in our dialogue with CSPA we are on the cusp of agreement on recommendations to consider in the legislation that would address two key needs in TSCA reform: balancing public access to chemical information with the need to protect legitimate confidential business information; and designing a system to provide EPA with more robust information on how chemicals are used for purposes of both prioritizing and assessing the safety of chemicals. I have come away from my deep involvement in these dialogues with the belief that there is not a single major issue in TSCA reform for which, working together, we cannot find a solution. . ."