On June 11, 2018, EPA published for public comment a draft guidance document entitled “Application of Systematic Review in TSCA Risk Evaluation.” The Toxic Substances Control Act (TSCA) requires EPA to make decisions on chemical risks based on the “best available science” and “weight of the scientific evidence.” This draft guidance presents a systematic review method for finding and assessing individual studies that EPA may consider in determining the risks posed by a chemical. The Environmental Protection Network is greatly concerned that EPA has drafted this seriously flawed systematic review process for TSCA. The guidance does not build on the 4 years of progress developed during the systematic review process for EPA’s Integrated Risk Information System, which has been endorsed by the National Academy of Sciences. EPN believes that the new TSCA process lacks key steps on how to integrate data from multiple studies; has not been developed in a transparent manner with the scientific community; and departs significantly from accepted principles for systematic review.
Read the full comments: EPN TSCA Risk Evaluation Comments