Statement of Daryl W. Ditz On Behalf of the Center for International Environmental Law Before the U.S House of Representatives Subcommittee on Commerce, Trade and Consumer Protection At a Hearing on Prioritizing Chemicals for Safety Determination

Daryl W. Ditz, representing the Center for International Environmental Law (CIEL), provided testimony to the U.S. House of Representatives on November 17, 2009, arguing that the Toxic Substances Control Act (TSCA) has failed to protect public health. Ditz proposed three primary reforms: authorizing the EPA to phase out high-priority chemicals (specifically PBTs), establishing a health-based safety standard for all chemicals where manufacturers bear the burden of proof, and mandating comprehensive, updated data submissions from chemical manufacturers to fill critical information gaps.

• The Toxic Substances Control Act (TSCA) is described as a failure that has not guaranteed the safety of most chemicals currently in use, hindering EPA action and undermining U.S. competitiveness.
• CIEL recommends that Congress authorize the EPA to promptly identify and phase out 'high-priority chemicals,' specifically those characterized as PBTs (persistent, bioaccumulative, and toxic). These chemicals are noted for defying traditional risk assessment because human exposure can increase even after production stops.
• The testimony advocates for a health-based safety standard for all chemicals, asserting that chemical manufacturers should carry the burden of proof to demonstrate their products are safe, while the EPA makes the final determination.
• Prioritization should be used only to determine the order of review, not to exclude any chemicals from scrutiny. Ditz criticizes the EPA's previous ChAMP initiative and the American Chemistry Council's principles for potentially allowing chemicals to avoid credible evaluation.
• To address massive data gaps, the U.S. should implement mandatory minimum data requirements for all chemicals, requiring manufacturers to provide information on physical and biological properties, as well as worker and environmental exposures.
• The document highlights the European Union's REACH regulation as a beneficial model for data generation, noting that data on approximately 3,000 high-volume chemicals was due by December 1, 2010.

APA

Ditz, D. W. (2009). Statement of Daryl W. Ditz On Behalf of the Center for International Environmental Law Before the U.S House of Representatives Subcommittee on Commerce, Trade and Consumer Protection At a Hearing on Prioritizing Chemicals for Safety Determination. Center for International Environmental Law. https://www.ciel.org/Publications/Ditz_Testimony_17Nov2009.pdf

Chicago

Ditz, Daryl W. Statement of Daryl W. Ditz On Behalf of the Center for International Environmental Law Before the U.S House of Representatives Subcommittee on Commerce, Trade and Consumer Protection At a Hearing on Prioritizing Chemicals for Safety Determination. Center for International Environmental Law, 2009. https://www.ciel.org/Publications/Ditz_Testimony_17Nov2009.pdf.

Wikipedia

{{cite press release |last1=Ditz |first1=Daryl W. |title=Statement of Daryl W. Ditz On Behalf of the Center for International Environmental Law Before the U.S House of Representatives Subcommittee on Commerce, Trade and Consumer Protection At a Hearing on Prioritizing Chemicals for Safety Determination |publisher=Center for International Environmental Law |date=17 November 2009 |url=https://www.ciel.org/Publications/Ditz_Testimony_17Nov2009.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{ditz2009statement, author = {Ditz, Daryl W.}, title = {{Statement of Daryl W. Ditz On Behalf of the Center for International Environmental Law Before the U.S House of Representatives Subcommittee on Commerce, Trade and Consumer Protection At a Hearing on Prioritizing Chemicals for Safety Determination}}, publisher = {Center for International Environmental Law}, year = {2009}, month = nov, url = {https://www.ciel.org/Publications/Ditz_Testimony_17Nov2009.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }