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GlobalChem 2021, which just wrapped up last month, was as important as ever for the chemical industry with a number of important announcements and excellent panel presentations. I recently had a chance to look back at my GlobalChem presentation from 2019, in which I forecasted how TSCA section 4 data collection would be needed to inform section 6(b) risk evaluations. Since then, the draft and final risk evaluations issued by EPA have predictably resulted in a growing appreciation for the need for high quality data. Attempts to provide data voluntarily have proved challenging. Arguably, section 4 compels EPA to demonstrate that it can and will rely on industry-provided data in its risk evaluations for information developed under this formal framework.
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