Chemical Processing - May 2008 - (Page 17)

COMPLIANCE ADVISOR << Biomonitoring continues to gain momentum CDC outlines criteria for removing chemicals from national report The CenTers for Disease ConTrol anD Prevention (CDC) recently announced final criteria for removing chemicals from the national report on human exposure to environmental Chemicals. such removal can relieve industry of a burden, so chemicals professionals should become familiar with these criteria. The importance of biomonitoring Biomonitoring measures chemicals in blood, urine, or other human bodily fluids and tissue. looking for chemicals in the body isn’t new, and finding them isn’t unexpected. What’s new is government agencies’ reliance on biomonitoring data. Vigorous and high-profile non-governmental organization (nGo) campaigns have recently taken the debate about the “harm” caused by chemical exposure to a new other chemical) is more representative of exposure than the one currently measured; or 2) if after three survey periods (not less than six years), detection rates for all chemicals within a method-related group are less than 5% for all population subgroups (i.e., two sexes, three race/ethnicity groups, and the age groups used in the report); or 3) if after three survey periods, levels of chemicals within a method-related group are unchanged or declining in all the demographic subgroups in the report. such evidence would be absence of a statistically significant (< 0.05) positive slope of mean (or geometric mean) levels over the time period. a chemical meeting criterion 1 would be removed from future reports and replaced with the new chemical that better reflects actual exposure. one meeting criterion 2 or 3 would be removed for two future survey periods (four years), then measured again in the following period (two years). if either criterion 2 or 3 is still satisfied for this 12-year period (three initial two-year survey periods, two intervening two-year survey periods, final two-year survey period), then it would be removed from the report and not reinstated unless it once again met the inclusion criteria. a chemical will be removed if it has: 1) an established federal biomonitoring health threshold (e.g., CDC’s level of concern for blood lead levels in children) or the CDC learns that a relevant federal agency considers it of sufficient priority to warrant continued monitoring; or 2) a long half-life, requiring more time to track changes reliably in population levels, or in exposure sources indicate future levels are likely to increase. The bottom line Tracking biomonitoring data will continue to gather momentum and regulatory interest. The role of these data in toxic tort suits shouldn’t be overlooked. if the criteria can be satisfied, businesses need to consider strategies to remove chemicals from the report, and possibly prevent adverse regulatory actions and legal inferences to be drawn from them. CP By Lynn Bergeson, regulatory editor. She is managing director of Bergeson Businesses need to consider strategies to remove chemicals from the report. and emotional level. While it’s undeniable that the presence of chemicals in our bodies is compelling information, it’s less clear what it means, and what health and safety inferences, if any, can be drawn. absence of clear regulatory guidelines to interpret these data adds to the confusion. CDC criteria The report provides an ongoing assessment of the U.s. population’s exposure to environmental chemicals using biomonitoring. Business operations, government agencies and nGos typically review the data on chemicals tracked in the report to discern any trends. Chemicals professionals will want to review the final criteria and assess whether they apply to chemicals of interest. The final criteria will be part of a combined process for nominating candidate chemicals for inclusion in or removal from the report, says CDC (for more information see www.cdc.gov/exposurereport/). Final criteria a chemical will be removed from the report if it meets any of the following criteria and doesn’t meet either exception: 1) a new replacement chemical (i.e., a metabolite or www.chemicalprocessing.com & Campbell, P.C., a Washington, D.C.-based law firm that concentrates on chemical industry issues. Contact her at lbergeson@putman.net. The views expressed herein are solely those of the author. This column is not intended to provide, nor should be construed as, legal advice. May 2008 • 17 http://www.cdc.gov/exposurereport/ http://www.chemicalprocessing.com

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From the Editor ChemicalProcessing.com Field Notes In Process Energy Saver Compliance Advisor WirelessHART signals a change at plants Avoid costly fabrication mistakes Watch out with variable speed pumping Hot cutover boosts control system migration Plant InSites Process Puzzler Equipment & Services Product Spotlight/Classifieds Ad Index End Point

Chemical Processing - May 2008

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