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Amended TSCA Impacts on OSHA: Product Stewardship Implications

Saturday, September 29 | 10:00 AM – 10:30 AM

Learning Level: Competent | Topic: Global Regulations

OSHA and TSCA are on a collision course. Unlike the past, amended TSCA requires chemical safety determinations by EPA to include workers as a “potentially exposed or susceptible subpopulation.” EPA and OSHA have traditionally used different assumptions to evaluate worker exposure and have taken different approaches for determining acceptable risk. Many of OSHA's risk assessments are not based on the latest toxicological data. Assuming worker exposure at the OSHA Permissible Exposure Limit (PEL) can yield predicted risks above levels that EPA finds to be acceptable. This sets up the possibility of EPA concluding, based on TSCA risk assessments, that workers face unacceptable risks at exposure levels assumed to be protective by OSHA for decades. Will EPA use their authority under Amended TSCA to require lower occupational exposure limits or additional restrictions that go beyond OSHA? What are the legal, hazard communication, and workplace implications on product stewardship?

Learning Objectives

  1. Understand EPA's authority to protect workers, beyond OSHA.
  2. Understand the differences between TSCA risk assessments and OSHA risk assessments of worker exposure to chemicals, and their outcomes.
  3. Develop strategies for product stewardship relative to upcoming changes in worker protection and worker communication challenges.
William Rish, Principal Engineer, ToxStrategies​