Regulating the introduction of new chemicals under section 5 of TSCA: improving the efficiency of the process and reducing potential injury in the workplace through the use of operational MSDS and exposure limits.

The Toxic Substances Control Act (TSCA) authorizes the EPA to take appropriate actions to ensure that new and existing chemicals do not pose "unreasonable risk" to health or the environment. Section 2(b)(3) of the Act directs the Agency to accomplish this objective in a manner that does "not impede unduly or create unnecessary economic barriers to technological innovation." In recent years, critics have felt that the EPA has failed to achieve these primary goals of TSCA. This paper considers some of the reasons for this criticism and advocates an alternate approach of exposure limits and operationally sufficient controls to assist in achieving these goals. An illustration of how this alternate approach might work under practical conditions is presented, using as an example a new chemical substance from the class of acrylate monomers. These concepts and risk assessments provide data for a better design of future studies according to good laboratory practice and quality assurance.