US industry group highlights concerns with EPA’s 'orphan' HPV proposal

The society's first concern is that the fourth HPV test rule, if finalised, could result in a clash with 2013 REACH registrations. The new proposal would require US manufacturers currently implementing tests for the EU deadline to test the same substances twice in order to meet the EPA's requirement for non-OECD test protocols. Socma highlights this would incur significant expense to generate information that is most likely already available, and argues that the EPA should accept data being generated for REACH and work closely with ECHA to leverage data it may already have.

In addition, Socma emphasises that it would be unfair to use SNURs to compel testing, as this could also result in a duplication of reporting, and is unnecessary.

The society concludes that EPA should continue to harmonise test protocols with other nations, and to formalise data-sharing agreements to enable it to utilise work already conducted outside of the US. The agency should also look to its enhanced chemical data reporting rule to address potential concerns with existing chemicals and to prioritise those chemicals.