Environmental Testing of Bisphenol A (BPA)
EPA released an advance notice of proposed rulemaking (ANPRM) (PDF) (13 pp. 266 kb, About PDF) on July 26 2011, requesting comment on requiring both toxicity testing and environmental sampling and monitoring to address the potential environmental effects of BPA.
EPA is asking for comment on requiring toxicity testing in ecologically relevant species to resolve existing scientific uncertainties concerning the potential for BPA to cause adverse effects, including endocrine-related effects, that could occur in environmental organisms at low doses. EPA is also considering requiring environmental testing consisting of sampling and monitoring, particularly in the vicinity of reported releases of BPA into the environment, to identify potential sources and pathways of exposure and to determine whether or not the concentrations to which organisms currently may be exposed are at or above levels of concern for adverse effects. These testing actions would be proposed under section 4 of the Toxic Substances Control Act (TSCA).
This ANPRM is one of several planned steps the Agency announced in the BPA Action Plan released on March 29, 2010. Other steps outlined in the Action Plan include an alternatives assessment on BPA in thermal papers, including cash register receipts, that began in July 2010 through the Agency’s Design for the Environment (DfE) program, and a proposal currently pending interagency review at the Office of Management and Budget (OMB) to list BPA under section 5(b)(4) of TSCA as a chemical that may present an unreasonable risk of injury to the environment.
As noted in the Action Plan, EPA does not intend to initiate regulatory action under TSCA at this time on the basis of risks to human health. Because most human exposure to BPA comes from food contact uses under the jurisdiction of the Food and Drug Administration (FDA), FDA has the lead on human health assessment. EPA remains committed to protecting human health and will continue to consult and coordinate closely with FDA, the Centers for Disease Control and Prevention (CDC), and the National Institute of Environmental Health Sciences (NIEHS) to better determine and evaluate the potential health consequences of BPA. The results of this assessment work will factor significantly in any future EPA decisions to address potential risks to human health resulting from uses within EPA’s jurisdiction.
Comments on the ANPRM must be received on or before September 26, 2011.