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The Risk of Ozone-Depletion Persists – Comments to EPA

EIA submitted comments to the U.S. Environmental Protection Agency (EPA) regarding the draft risk assessments of methylene chloride, carbon tetrachloride, and other priority chemicals undergoing risk evaluations under the Amended Toxic Substances Control Act (TSCA). Mounting scientific evidence points to rising emissions of short lived substances and their potential impact on delayed recovery of the ozone layer. Continued rising methylene chloride emissions alone have the potential to delay healing of the ozone layer by up to 30 years. In these comments, EIA strongly urges the EPA to examine ozone depletion as a risk to human health and the environment in evaluating methylene chloride, carbon tetrachloride, and all other chlorinated and brominated chemicals. Rapidly rising emissions of these chemicals can significantly delay recovery of the ozone layer. We further recommend that the EPA consider all available scientific information regarding observed global and regional emission trends and concentrations of these substances when considering their risks, and not to rely solely on industry reported data. Finally, we urge the EPA to evaluate and subsequently further regulate the production and intermediate uses of these chemicals under TSCA to avoid unreasonable risk to human health and the environment.

Download our comment: Ozone Depletion Risks Posed by Emissions of Methylene Chloride, Carbon Tetrachloride, and Other Short-lived Chlorinated and Brominated Chemicals Under Evaluation by the Amended Toxic Substances Control Act (TSCA)

Download our comment: Gaps in Clean Air Act leave the Amended Toxic Substances Control Act (TSCA) responsible for Ozone Depletion Risk in the Assessment of Carbon Tetrachloride and Other Chlorinated and Brominated Chemicals Under Evaluation”