A session at the American Industrial Hygiene Conference and Exposition (AIHce) held this week in San Diego addressed the impact of the program from the perspective of labor, EPA, the chemical industry trade associations and manufacturers.
In 1998, then-EPA Administrator Carole Browner and the Environmental Defense Fund challenged the chemical industry to voluntarily provide basic toxicity information on their high production volume (HPV) chemicals. HPV chemicals are those chemicals that are produced in or imported to the United States in amounts over 1 million pounds per year. The companies in the chemical industry accepted the challenge, agreeing to adopt and test the chemicals on the HPV list, and allow the information generated through the Voluntary Challenge Program to be posted to EPA's Web site.
Following the guidance established by EPA, participating companies assess the adequacy of existing data; design and submit test plans; provide test results as they are generated; and prepare summaries of the data characterizing each chemical.
"Of the HPV with OSHA PEL's, only 52 percent have data for all four Screening Information Data Set (SIDS) human health endpoints," Dan Caldwell of ExxonMobil Biomedical Sciences Inc. told the AIHce audience. "Only five percent had data for all four SIDS human health endpoints."
SIDS includes information on the identity of the chemical, its physical and chemical properties, uses, sources and extent of exposure, environmental fate (for example, whether it degrades quickly and how it might be distributed throughout the environment), and limited toxicity data for humans and the environment.
The HPV Challenge uses the same tests, testing protocols, and basic information summary formats as SIDS, a cooperative, international effort to secure basic toxicity information on HPV chemicals worldwide. Information prepared for this US domestic program will be acceptable in the international effort as well.
Steven Russell, counsel for the American Chemistry Council said there are sponsor commitments for 2,200 U.S. HPV chemicals, roughly 1,400 through the U.S. HPV Challenge program, and approximately 800 through an initiative sponsored by the International Council Chemical Association (ICCA).
"There are 804 chemicals posted on EPA's Web site, 600 to go by 2004," he said, of the efforts made by U.S. chemical companies.
The program has had an impact on the chemical industry, he told audience members, noting:
- An increased emphasis on product stewardship (responsible care, consequences of manufacturing HPVs)
- Increased transparency (greater public availability of research data on health and environmental impact of chemicals)
- More data/assessments coming
- Hazard-based product challenges
- The creation of uniform electronic databases
- Greater need for risk-based communication with employees, customers and users.
"Probably the only group more interested in the HPV program [than the chemical industry] are environmental groups, who are watching this program very carefully," said Russell.
Michael Sprinkler, an industrial hygienist with the International Chemical Workers Union, brought the labor perspective to the discussion. "A lot of times on environmental issues and testing, the worker perspective is left out," he noted. Quoting a Harvard scholar he added, "The best way to predict the future is for us to make the future."
He cautioned that workers need to be educated about the HPV Challenge, and what the data means to them. The role of the union, he said, was to "represent the needs of workers and their representatives for good HPV chemical information."
He pointed out that some of the HPV challenge files listed on EPA's Web site were so large (7 MB or larger) that many people probably wouldn't even try to download them. "It's hard for folks without a fast computer," he said, noting that made it all the more important to determine "how to convey complex HPV info to 'normal' people" such as workers, supervisors, engineers, health and safety professionals and the general public.
"We need to conduct training using non-toxicologist terms," said Sprinkler. "Teaching using small group activities, and the more information, the better."
"We talk about literacy being important," he noted. "Technical literacy is important too."
If the education of workers is successful, he added, the chemical industry will benefit because workers will understand how to substitute less hazardous chemicals, will be able to identify exposure risks, and will be able to identify dangerous reactions before they can occur.