On May 17, 2019, EPN submitted comments on 24 studies EPA released for the draft risk evaluation of Pigment Violet 29 (PV29), urging the agency to use its authority under the Toxic Substances Control Act (TSCA) and not make a determination of “no unreasonable risk” on PV29, or any chemical, based on proprietary information—a precedent-setting decision that could endanger public health and the environment.
As background, on November 15, 2018, the EPA announced that it was seeking public input on the draft risk evaluation for PV29, the first evaluation to be done under the reformed TSCA. PV29 is primarily used as a colorant in inks, paints, coatings, and plastics. Initially, EPA refused to make public the underlying health and safety studies for PV29, only providing copies of and links to brief summaries, which were prepared by companies that make PV29. EPA claimed the studies had to be withheld because they were protected as confidential business information (CBI) under TSCA – a position that is contradicted by the plain text of the law. EPN members submitted comments on the TSCA risk evaluation of PV29, highlighting the improper use of TSCA CBI discretion. Thanks to our comments and those of others, EPA announced the release of 24 PV29 studies, with redactions, and reopened the comment period.
Read a summary of the comments: Summary on Review of BASF PV29 Studies
Read the full comments: Comments on Review of BASF PV29 Studies