CPMA Continues Efforts to Correct EPA’s Risk Evaluation Process

Written by David Wawer, Executive Director, CPMA

What exactly are the impacts of EPA's risk evaluation and risk management processes for color pigments on the North American supply chain? The Agency is reaching inaccurate risk determinations through incorrect data, and driving up costs in numerous ways.

This was the emphasis of CPMA Executive Director Dave Wawer's recent presentation at the National Association of Printing Ink Manufacturers (NAPIM) Fall Technical Conference, and an ongoing focus of regulatory efforts for the association that is the voice of the North American color pigments value chain.

Intentionally or unintentionally, the EPA is building a chemicals risk evaluation and risk management process that will add increased costs to manufacturers, processors, distributors, and ultimately, the consumer. On the surface, the approach appears to be consistent with the Lautenberg Chemical Safety Act of 2016. When you conduct an analysis of the EPA “work product” to date (completion of 10 chemical risk evaluations after six years), and resources (time and cost) for manufacturing companies and EPA personnel to be engaged in the process, a significant process cost per chemistry is clear.

Examples of inflationary impacts include:

  1. EPA’s FY budget request for hundreds of millions of new Federal spending to “fund” chemicals risk evaluation & risk management
  2. EPA’s proposal to increase TSCA risk evaluation fees from $1.2mm per chemistry to $2.5mm (or more) per chemistry
  3. EPA’s requirements for additional new data studies as part of the risk evaluation process, which carry a significant cost burden to manufacturers and processors
  4. EPA’s risk management rules adding significant new “regulatory costs” to manufacturers, processors, and distributors, which will lead to inflated costs to consumers.

Outcomes of the risk management process for CI Pigment Violet 29 will determine whether significant new regulatory costs are required for printing ink manufacturers, printing companies, packaging manufacturers, and consumer products companies. Ultimately, such regulatory impacts along the color pigments value chain could result in new inflationary costs for the consumer.

For further expert insight and to learn about CPMA's continued efforts to educate, inform and collaborate with industry stakeholders and federal agencies to ensure accurate science, contact Dave Wawer at davidwawer@cpma.com.

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