13. Environmental Protection Agency · Notable
Use real-world chemical use in conditions-of-use assessments
Printed page 434 13. Environmental Protection Agency
“Apply real-world use of chemicals when assessing conditions of use for risk evaluations.”
What has happened
- Partially done
EPA proposed to return to the 2017 approach of making a determination of unreasonable risk for each condition of use rather than a single whole-chemical determination, and to remove the 2024 requirement that every condition of use and every exposure route and pathway be considered without exception. Its stated ground is that the 2024 rule is not the best reading of the statute and impedes timely evaluations. It is a proposal; risk evaluations published through 2026-08 are still made under the 2024 rule.
- Attempted
Executive Order 14303 requires agencies to evaluate "the realistic or reasonably foreseeable effects of an action" and to avoid overly precautionary scenarios unless the law requires them — the general form of the Quote's ask, issued government-wide and with no effect on a conditions-of-use assessment by itself.
Research log
What was searched, and what didn’t count as evidence
Research notes
- One negative search covered the OCSPP chemicals and pesticides asks on pp. 433-435.
- The Quote’s “real-world use” maps onto two things in the proposal: the per-condition-of-use determination and the removal of the obligation to sweep in every reasonably foreseen pathway. Both are proposed.
- Action
- other
- Object
- conditions of use in TSCA risk evaluations
- ID
- 1143