ACC’s 1,3 Butadiene TSCA Risk Consortium: EPA’s Draft TSCA Risk Evaluation for 1,3 Butadiene Does Not Meet Scientific Standards

WASHINGTON (Dec. 3, 2024) - Today, the American Chemistry Council's 1,3-Butadiene TSCA Risk Consortium issued the following statement on the U.S. Environmental Protection Agency's (EPA) completion of a draft Toxic Substances Control Act (TSCA) risk evaluation for 1,3-Butadiene:

"We recognize the EPA's effort to generate a comprehensive risk evaluation for 1,3-Butadiene and appreciate the opportunity to assess the application of best available science in the draft evaluation. While we are still reviewing the draft documents in detail, we have significant concerns regarding the underlying science used in the draft evaluation and the short timeline for the peer review by the Science Advisory Committee on Chemicals (SACC).

"Over the past two decades, substantial scientific research on 1,3-Butadiene has been conducted and it is important to allow for a robust stakeholder review to evaluate EPA's use of this information in the analyses presented in the draft documents. TSCA mandates that risk evaluations be based on the best available science and the weight of the evidence. This extensive body of research must be fully evaluated for the EPA to develop a risk evaluation that meets TSCA's scientific standards.

"Furthermore, the EPA has scheduled the SACC peer review for February 25-28, 2025, and has yet to populate the SACC or even see if designated peer-reviewers are available. This will not provide sufficient time for the SACC to review and consider any public comments. This combined with the extremely short timeline for commenting on the draft is inappropriate, as it encompasses multiple religious and secular holidays in December and the start of the new year, further reducing the time available for stakeholders, Consortium members, and SACC experts to review these important and highly technical documents.

"1,3-Butadiene is a critical chemistry that supports industries across our economy, including over half a million jobs and products for essential sectors such as national defense, healthcare, agriculture, infrastructure, and more. An overly conservative TSCA risk evaluation that does not incorporate the best available science could have significant consequences for American manufacturers, downstream users, consumers, and key industries.

"Given that 1,3-Butadiene is typically reacted in the manufacturing process and further processed to create a wide range of end goods, the potential for consumer exposure is very low. This substance is already extensively regulated to protect human health and the environment, with requirements codified by the Occupational Safety and Health Administration (OSHA), EPA, state environmental agencies, and other regulatory bodies governing its safe production, storage, handling, and use.

"We look forward to continued engagement with the EPA and urge the Agency to reconsider this short timeline to allow stakeholders to adequately address the key scientific issues and questions resulting from this draft evaluation."