The American Cleaning Institute (ACI)

Toxic Substances Control Act

Obama signing a document

In 2016, after years of science-based advocacy from ACI, industry partners and stakeholders, President Obama signed the Frank R. Lautenberg Chemical Safety for the 21st Century Act.

ACI's goal in TSCA modernization was to ensure members’ ability to innovate and formulate. ACI is committed to targeted risk-management measures that focus priorities and are practical, timely, transparent and responsive to the needs of consumers and other stakeholders.

ACI was a leader among allied associations and manufacturers in bringing industry chemical modernization priorities to the forefront legislatively and at the executive branch level. Getting to this point represents an effort spanning several years, engaging many members of congress, industry and nongovermental groups who worked diligently and in good faith to develop a genuine compromise.

ACI's Involvement

March 20, 2017 - ACI comments to Environmental Protection Agency, Procedures for Prioritization of Chemicals for Risk Evaluation Under TSCA:

ACI told the Agency that we support "EPA’s efforts to articulate and establish a process for prioritizing substances for review under the amended TSCA. ACI encourages EPA to a) make clear the standards it will apply in the pre-prioritization process, b) use a flexible approach when interpreting how it will make the Low-Priority designation, and c) arrive at final prioritization procedures under the proposed "framework" rules that will enable the Agency to adopt a bold vision and approach by which EPA will make determinations to identify large numbers of Low-Priority substances swiftly using the information and data currently available on such substances."

March 20, 2017 - ACI comments to Environmental Protection Agency, Procedures for Chemical Risk Evaluation Under the Amended Toxic Substances Control Act:

In written comments, ACI encourages "EPA to consider the two operations, Prioritization and Risk Evaluation, to be closely linked and believes the Agency should use the processes as a means to swiftly sort out large groupings of chemicals and chemical-use combinations that do not require the most immediate attention, and then to concentrate its Risk Evaluation resources and efforts on those substances and conditions of use that are the most likely to present the greatest risk on the basis of factors considered and identified during the prioritization process. This requires that the Agency must be willing to use a flexible approach that will enable EPA to sort large groups of substances in a manner that will recognize and temporarily remove from detailed consideration (or information gathering efforts) lower priority substances and conditions of use combinations.

"Likewise, the closer review of high priority substances requires the Agency to effectively and narrowly define the scope of the Risk Evaluations it intends to undertake. This is the most productive way in which EPA will be able to focus its limited resources on those chemical and use combinations of greatest concern. Doing so will permit EPA to undertake and complete Risk Evaluations more readily and will not unnecessarily obligate the Agency to identify and immediately assess all foreseen uses of a substance and all potential opportunities for exposures to a substance at the same time. ACI encourages EPA to avoid overburdening itself in favor of undertaking and completing more targeted Risk Evaluations in a credible manner that will rely on the information available to EPA and reflect the use of sound science while applying a weight of the evidence approach."

March 14, 2017 - ACI comments to Environmental Protection Agency, TSCA I

View Ernie Rosenberg’s testimony before the House Subcommittee

View the House subcommittee Q&A session with a panel of witnesses, including ACI’s Ernie Rosenberg


 A chemical nomenclature is a set of rules to generate systematic names for chemical compounds. In the case of chemicals derived from fats and oils, multiple naming systems exist.

The Toxic Substances Control Act (TSCA) requires EPA to "compile, keep current, and publish a list of each chemical substance which is manufactured or processed in the United States." Since the initial TSCA Inventory was compiled in 1979, EPA has developed policy statements and guidance documents on how to identify certain chemical substances for the purpose of assigning unique and unambiguous descriptions for each substance listed on the Inventory. 

The following are links to relevant nomenclature guidances:

1995 - Toxic Substances Control Act Inventory Representation for Certain Chemical Substances Containing Varying Carbon Chain Lengths (Alkyl Ranges Using the CX-Y Notation)

1995 - Toxic Substances Control Act Inventory Representation for Chemical Substances of Unknown or Variable Composition, Complex Reaction Products and Biological Materials: UVCB Substances

1979 - SDA Substance Identification Procedure, Appendix A, Toxic Substances Control Act Chemical Substances Inventory, Initial Inventory, Volume 1