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

The statement argues that the Toxic Substances Control Act (TSCA) has failed to ensure chemical safety and proposes three primary reforms: authorizing the EPA to phase out high-priority persistent, bioaccumulative, and toxic (PBT) chemicals; establishing a health-based safety standard for all chemicals where manufacturers bear the burden of proof; and mandating that manufacturers provide comprehensive, up-to-date data on chemical hazards and exposures. The author emphasizes that prioritization should determine the order of review rather than exclude chemicals from scrutiny, citing the failures of the EPA's ChAMP initiative and the potential benefits of aligning with the European Union's REACH regulation.

• The Toxic Substances Control Act (TSCA) is described as a failure that has not guaranteed the safety of most chemicals in use and has hindered the EPA's ability to take action.
• The author recommends that the EPA be authorized to promptly phase out 'PBT' chemicals—those that are persistent, bioaccumulative, and toxic—because they defy traditional risk assessment as human exposure can increase even after production stops.
• A proposed reform suggests that chemical manufacturers, rather than the government, should carry the burden of proof to demonstrate that their products are safe based on a health-based standard.
• Prioritization should be used only to determine the sequence of safety reviews, not to exempt any chemicals from evaluation, to avoid repeating the mistakes of the EPA's ChAMP initiative where chemicals were wrongly labeled 'low risk'.
• The document calls for mandatory minimum data requirements for all chemicals, noting that voluntary industry programs have left hundreds of high-volume chemicals without basic screening data.
• The author suggests the U.S. can benefit from the European Union's REACH regulation, which is generating public hazard data on approximately 3,000 high-volume chemicals 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} }