POPs, PIC, and LRTAP: The Role of the U.S. and Draft Legislation to Implement These International Conventions

The document provides testimony from the Center for International Environmental Law (CIEL) and partner organizations criticizing a draft bill for implementing international chemical conventions. The authors argue the draft decouples international and domestic processes, imposes restrictive cost-benefit standards, and introduces 'sound science' requirements that could hinder the EPA's ability to regulate hazardous chemicals. It also refutes Bush Administration claims that mandatory implementation of international listing decisions would violate the U.S. Constitution.

• The June 17, 2004 Discussion Draft is criticized for failing to require the EPA to act within a specific timeline or provide reasons for inaction following an international decision to add a POP to the Convention.
• The authors argue the Discussion Draft would force the EPA to conduct duplicative scientific assessments, ignoring the rigorous international investigations already required by the Stockholm Convention.
• The proposed regulatory standard in the draft requires a 'reasonable balance' of costs and benefits, which the authors claim contradicts the 'precautionary manner' required by the Stockholm Convention and favors corporate interests.
• The document warns that 'sound science' requirements in the draft are tools used to delay regulation and should be omitted to prevent politically motivated 'scientific certainty' tests.
• The authors object to provisions in the draft that would prohibit the EPA from regulating more strictly than the minimum Convention standards, effectively forcing the U.S. to accept exemptions intended for developing countries.
• The testimony refutes the Bush Administration's 'international non-delegation doctrine' claim, asserting that Congress can legally make domestic agency action contingent upon international events, citing precedents like the Clean Air Act and the Tariff Act.

APA

Wiser, G. M. (2004). POPs, PIC, and LRTAP: The Role of the U.S. and Draft Legislation to Implement These International Conventions. Center for International Environmental Law. https://www.ciel.org/wp-content/uploads/2015/05/Wiser_Hearing_July04.pdf

Chicago

Wiser, Glenn M. POPs, PIC, and LRTAP: The Role of the U.S. and Draft Legislation to Implement These International Conventions. Center for International Environmental Law, 2004. https://www.ciel.org/wp-content/uploads/2015/05/Wiser_Hearing_July04.pdf.

Wikipedia

{{cite press release |last1=Wiser |first1=Glenn M. |title=POPs, PIC, and LRTAP: The Role of the U.S. and Draft Legislation to Implement These International Conventions |publisher=Center for International Environmental Law |date=13 July 2004 |url=https://www.ciel.org/wp-content/uploads/2015/05/Wiser_Hearing_July04.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{wiser2004pops, author = {Wiser, Glenn M.}, title = {{POPs, PIC, and LRTAP: The Role of the U.S. and Draft Legislation to Implement These International Conventions}}, publisher = {Center for International Environmental Law}, year = {2004}, month = jul, url = {https://www.ciel.org/wp-content/uploads/2015/05/Wiser_Hearing_July04.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }