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Update: Toxic Substances Control Act


Update: Toxic Substances Control Act

by Brenda Adelman

We are surrounded by toxins

The new Sonoma County Recycling Guide lists common household toxics needing to be stored, used, and disposed of with care, such as antifreeze or other auto fluids, fuels such as gasoline, kerosene and lamp oil, along with paint thinners, solvents, and wood finishes. Pesticides and weed killers are included also. 

In the kitchen and bath dwell assorted cleaners, cosmetics, drain openers, aerosol sprays, and of course pharmaceuticals. Medications ending up in the waste stream at very low levels continue to be biologically active and capable of causing harm to humans, pets, fish and other aquatic life coming in contact with it. Even most effluent passing through advanced wastewater treatment systems such as reverse osmosis and advanced membrane technology, retain remnant toxins. Experts have stated that no existing treatment technologies eliminate all toxins.

Toxins much too common in food and cosmetics

Harmful chemicals are also found in our food.  For example, a recent alert from Environmental Working Group (EWG) stated that, “…propyl paraben, a preservative linked to endocrine disruption and not allowed in food sold in the European Union, is in nearly 50 U.S. snack foods, including Sara Lee cinnamon rolls, Weight Watchers cakes….etc.” While some cosmetic companies have removed propyl paraben from their formulations, food companies have not followed suit. 

Cosmetic companies are weakly regulated. A recent article entitled “Bill Would Give F.D.A. More Muscle on Cosmetics” (Rachel Abrams, Business Day, April 20, 2015) states: “Regulating cosmetics has not changed much since passage of the Food, Drug and Cosmetic Act in 1938. The F.D.A. can only ask companies to voluntarily recall products, and manufacturers are not legally required to disclose adverse health effects reported by consumers.” 

A new bill recently proposed by Senators Sue Collins and Dianne Feinstein is called the Personal Care Products Safety Act and would give Food and Drug Administration (FDA) broader oversight in regulating cosmetics. FDA would be required to investigate five potentially risky ingredients each year, (Note: If there are 85,000 chemicals in existence, can this be nearly enough?) and if found to pose health risks, FDA could ban or restrict use. EWG strongly backs this legislation and states, “Many Americans are surprised to learn that the ingredients in their makeup, shampoo and body lotion are largely unregulated and, in some cases, harmful to their health…” (Note: Environmental Working Group maintains website that provides very useful information on toxins in personal care products, food additives, cleaning products, and much more at

Fish are affected also

Many of these toxins are not only dangerous for humans, but they get into the food chain through the fish we eat. In a notice released by United States Geological Survey on March 24, 2015, entitled “Laboratory Study Shows Future Generations of Fish Affected by Endocrine Disruptor Exposure”, and states, “Fish exposed to the endocrine-disrupting chemicals bisphenol A (BPA) or 17a-ethinylestradiol (EE2) in a laboratory have been found to pass adverse reproductive effects onto their offspring up to three generations later…..”  

They add, “Aquatic environments are the ultimate reservoirs for many contaminants, including chemicals that mimic the functions of natural hormones.  Fish and other aquatic organisms often have the greatest exposures to such chemicals during critical periods in development or even entire life cycles.”  They found that subsequent generations were more affected by the toxins than the fish experiencing the original exposure. Some studies have indicated the same response in humans when pregnant women are exposed to these toxins. Their grandchildren and great grandchildren may be more affected than their own child. (Note: in the case of fish, they live in river toxins 24/7, and never get relief from constant exposure.)

Endocrine disrupting chemicals

Many household and personal care products are endocrine disruptors (Note: see list: Laura Vandenberg PhD, Environmental Health Scientist at University of Massachusetts at Amherst, notes that after twenty years of peer reviewed scientific studies, that include many controlled experiments with animals showing clear links between environmental exposures to toxins and endocrine disruption affects on wildlife reproduction, there is no question that extremely low doses can affect functions of the endocrine system. There are also many human epidemiological studies that provide similar evidence.  

This is in contrast to current risk assessment assumptions that ascertain the dose makes the poison and the goal is to discover the safe dose at which no adverse effects occur. This assumption has now been turned on its head with endocrine disrupting chemicals and very low dose exposures (in some cases, in the parts per trillion range, can have critical impacts.

Proposed toxics legislation

The Toxic Substances Control Act (TSCA) was passed in 1976 and provided Environmental Protection Agency (EPA) with authority to require reporting, record-keeping, and testing requirements, along with restrictions relating to chemical substances and/or mixtures, but excluded food, drugs, cosmetics & pesticides. Since that time, EPA has required safety testing for just 200 of the estimated 85,000 chemicals in existence, with only five having been banned or restricted out of all those currently registered for use. We have no information on the many new toxins formed within those 85,000 through combination with one another. 

There are significant differences between two pieces of proposed legislation to update TSCA,  that have come forward from the House and the Senate.  The Markey-Boxer Senate Bill version of the update is titled “The Alan Reinstein & Trevor Schaefer Toxic Chemical Protection Act”. The House version is proposed by Tom Udall of New Mexico and David Vitter of Louisiana.  

This latter bill is believed to have been influenced by the chemical industry and would take away States’ rights currently allowing them to create their own toxics legislation and thereby undermining current regulations. Furthermore, EPA is concerned this House version might be exploited by the industry by delaying review of very hazardous toxic chemicals indefinitely while EPA is forced by this legislation to review less hazardous chemicals requested by industry, thereby taking away resources that are needed for more dire toxicity evaluations. (Note:  There are numerous other substantive issues that will need to be covered in future Gazette articles.)

The Boxer-Markey Bill would require EPA to use stronger safety standards, require immediate attention on chemicals that accumulate in our bodies and the environment, assure consistency with recommendations from the National Academy of Sciences, preserve EPA’s authority to regulate products and mixtures containing dangerous chemicals, and more…..

This article is only a small part of the story, which will be continued in future articles.  Send questions to Brenda at Donations to RRWPC are greatly appreciated  - RRWPC and mailed to P.O. Box 501, Guerneville, CA 95446.



Vesta; we would like to thank you for printing Brenda Adelmans article on the toxic substance control act. This took real courage on your part.  
This extremely well written article really ties into the message about humans, marine life and pollution that we bring. DR. Chellsea Rochman in a 4yr. study on both farmed and ocean caught fish has found that micro plastics in the ocean (80% of the plastic in the ocean is storm drain driven) get caught in their gills, mimic the nutrients the fish need and are absorbed. She also found that 100% of  fish test positive for the chemicals found in plastics and Styrofoam . These include pcbs. phenols and phthalates. these chemicals when consumed by female humans or marine mammals mimic the nutrients that it takes to build a new body are absorbed by the girl, lodge in the fat layer under the skin,  and when she conceives her body releases these chemicals to feed and build her new baby. This is how the plastic that we walk by today will affect our grand and great grand children. As these poisons can skip a generation.
So what are these effects? 
We will take just one phthalates; D.E.H.P. commonly found in both food packaging and fish. Lead researcher  Dr. Shawna Swan from the Mt. Siani Hospital Medical School studied the effects of D.E.H.P. on the developing fetus and the threat they pose to male reproductive life later on. She found that fetuses exposed to D.E.H.P. showed incomplete masculinization. It also correlates to a lessening in size, sperm count, and fertility. All human fetuses that were tested, tested positive for D.E.H.P.!. D.E.H.P. is also listed in the 13th report on carcinogens, which means it causes cancer. Which leads us back to sea lions.
Dr. Frances Guland while lead scientist for the Marine Mammal Center did a study on genital cancers in Ca. sea lions. She found that 30% of all sea lions are affected with a cancer resulting from the condensing of petro chemicals from plastic and DDT in the fish that the sea lions consume. These endocrine disruptors are a teratogen resulting in a lymph cancer in their pups. These babies never reach breading age.
Couple this with over fishing; warming of the ocean, along with 11 different diseases, 12 different parasites, and 2 more types of cancer both human induced, not to mention those shot and clubbed to death by the fishing industry. One can clearly see that the entire species is in trouble and if we humans don't give them relief from the stress we have put them under we are going to exterminate them. We have had 5 die offs in the last 6 yrs. that should be a clue.
How can people help? DONT EAT FISH. and talk to your grocer about packaging. Change will only happen if we make it happen.
Vesta I would again like to thank you for the courage you have shown in publishing articles and letters from "extreme environmentalists" you can suffer push back from the petroleum industry, the plastics industry, and the fishing industry. It is the fisherman that has been hurt the most of the 3, it is their livelihood that has been poisoned. You can make plastic out of vegetable oil but you can only make fish out of fish.
Keary and Sally Sorenson