In 1990, with extensive participation by industry, the OECD defined criteria for minimal toxicity screening information for a chemical. EDF ignored these environmental criteria and limited its study to human health effects. Thus the EDF study, again, very likely overstates the availability of minimum toxicity information. It is important to note, as EDF says, that the minimal OECD screening information for human health does not include sufficient information to conduct a comprehensive health risk assessment. Obviously, TSCA has failed.
Control can include anything from a labeling requirement to an outright ban.
Obviously, 'substantial' exposures cannot be proven if quantitative information on releases of the chemical or exposures to the chemical is lacking. And 'significant' exposures cannot be proven without information on the chemical's toxicity. EPA then has 45 days in which to challenge the manufacturer to provide more test data. More than half of all PMNs are submitted without any toxicity data. The contents of a PMN are not binding and thus there is no incentive for a manufacturer to insure that its original submission is accurate or reliable.