ACROSS THE POND Assessing REACH's First Big Impact on U.S. ...

ENVIRONMENTAL DEFENSE FUNDLimitations to IUR Data• Many exemptions, e.g.:– Production for non-TSCA regulated uses– Polymers– R&D chemicals– Chemicals imported as part of an article– Non-isolated intermediates– Small manufacturers• Dated and only 1 yr (2005), despite large fluctuations• High threshold of 25,000 pounds per site• Public can’t t see CBI chemicals/companies/sites9