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The report by Senior Health Program Scientist Richard A. Denison, Ph.D., gives overall grades of C-minus to EPA and D to the chemical industry for their performance in the High Production Volume (HPV) Chemical Challenge (see report cards below). Under the program, manufacturers were asked to volunteer to develop and make publicly available a "base set" of screening-level hazard information on HPV chemicals, those produced in or imported into the U.S. in amounts of one million pounds or more annually.
"The challenge has failed to produce much of the data it had promised to deliver well before now," said Denison. "Equally disturbing are the decline in the average quality of the chemical industry's submissions over time, and that data gaps remain even in final submissions."
Denison's report, "High Hopes, Low Marks: A Final Report Card on the High Production Volume Chemical Challenge", documents a series of shortcomings. Many companies are years late in providing the promised data and the government faces big hurdles in filling remaining data gaps and addressing data quality concerns. Since the HPV Challenge is voluntary, EPA has limited recourse to ensure full participation by manufacturers or the timely submission and high quality of hazard data sets. As a result:
- Two-and-a-half years after final data sets were due, fewer than half (47 percent) have been submitted.
- 10 percent of eligible HPV chemicals were not volunteered for the challenge by the companies that produce them; EPA has issued rules to compel testing for only 6 percent of these chemicals.
- The grade point average for initial industry submissions has declined from a solid B-plus in 2001 to a C-minus in 2006.
High Hopes, Low Marks also discusses the status of two essential next steps: EPA's assessment of the Challenge data, where it is making good progress, but is also finding that data gaps remain even in final submissions; and a failure by industry to commit to develop data for most of the nearly 600 chemicals that have reached HPV levels since the challenge was launched. Important "lessons learned" for the design and execution of voluntary environmental initiatives are provided.
CHEMICAL INDUSTRY, OVERALL GRADE D Extent of sponsorship of HPV chemicals B+ Extent of initial submissions B- Extent of final submissions F Quality of initial submissions C+ Providing public access to information F USEPA, OVERALL GRADE C- Extent of test rule development for orphans D Extent of EPA review of initial submissions B- Providing public access to information C-
The report is available online at http://www.environmentaldefense.org/hpvreportcard.