NACWA submitted two comment letters March 20, on EPA rule proposals related to chemical risk evaluations required by the Frank R. Lautenberg Chemical Safety for the 21st Century Act, passed in 2016 to reform the Toxic Substances Control Act (TSCA).  The law requires EPA to systematically prioritize and assess existing chemicals and manage identified risks.  EPA’s first step will be prioritization of chemicals for risk evaluation, followed by the risk evaluation that will consider multiple factors. 

NACWA’s comments on the proposed rule for prioritization recommended that EPA’s process allow prioritization based on a chemical’s adverse effects on a utility’s effluent quality, wastewater treatment processes, and ability to reuse or recycle materials resulting from wastewater treatment, such as recycled water and biosolids.  NACWA also asked in its comments on the proposed rule for chemical risk evaluation, that EPA consider the effects of cumulative use of chemicals in numerous products that could be discharged to a wastewater treatment facility. 

NACWA will continue to follow the implementation of the new TSCA requirements and their impacts on clean water agencies.  NACWA members with questions or input on chemical evaluations should contact Cynthia Finley.