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Chemical Prioritization Process

Kat Gale

In 2019, 20 chemicals were identified as a high-priority candidate chemicals for TSCA risk evaluation 1. It is important to note that a designation of these chemicals as a high-priority chemical “does not constitute a finding of risk” and should not be cause for concern. A high-priority designation simply means the EPA has nominated the chemical for for risk evaluation.

In order to complete an accurate TSCA risk evaluation, determining the levels at which these chemicals from occupational, commercial and consumer exposures might cause adverse effects is critical. Central to this challenge is proper evaluation and integration of the entire body of scientific evidence, including human, animal and mechanistic information to draw conclusions regarding risk. This is done through a systematic review process, which is required by the 2016 TSCA amendments. A systematic review process is a pre-established set of protocols that comprehensively, objectively, transparently, and consistently identifies and evaluates evidence based on quality and relevance.

There are a number of recently completed, peer-reviewed studies 2 that have meaningfully advanced the body of scientific evidence related to understanding these chemistries. Given the thousands of peer reviewed scientific articles that have been published, and dozens of chemical reviews that have been conducted by federal and international agencies, it is crucial for evaluations to rely upon the highest quality and most relevant information when determining risk.

If EPA follows the required science protocols in conducting these risk evaluations, using the best available, highest quality and most relevant data will demonstrate that the responsible uses, and any potential exposures, continue to be properly managed

1 EPA Hits Another TSCA Milestone with High Priority Designations

2 ACC Research Library


TSCA requires the use of the best available science, meaning that information must be of the highest quality in order to be included in the reviews. This type of evidence includes information on the hazard and exposure potential of the chemical substance; persistence and bioaccumulation; potentially exposed or susceptible subpopulations; the conditions of use or significant changes in the conditions of use of the chemical substance; and the volume or significant changes in the volume of the chemical substance manufactured or processed.

EPA has made clear that designation as a high priority chemical “does not constitute a finding of risk” and should not be cause for concern.

A $1.35 million fee for each EPA-initiated risk evaluation will be divided among companies that have manufactured or imported the chemical substance in any volume in the past five years, including companies that have imported articles containing that substance.

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