The VCCEP: Big Issues, High Stakes (PDF)

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Courtesy of Bergeson & Campbell, P.C.

It’s almost here, and it’s big. The Voluntary Children’s Chemical Evaluation Program (VCCEP) is EPA’s newest “voluntary” initiative designed to obtain hazard and exposure information to characterize adequately risks of chemical exposure to children. EPA is poised to roll it out imminently.  The VCCEP is controversial, precedent setting, and breathtakingly significant for chemical producers and certain product manufacturers alike.  As of this post-election writing, EPA makes no commitments as to when the Program will be issued in final, only that it expects to do so soon, perhaps this calendar year. While presidential election uncertainty casts some doubt on the political viability of the VCCEP, given how far down the road EPA is with the Program and broad stakeholder buy-in (at least in some quarters), it may be too late to pull it back regardless of who wins the election. This article describes the major features of the VCCEP as described by EPA in stakeholders meetings conducted this Fall, and outlines the issues fueling the debate around why this Program is so significant.

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