Low marks for voluntary chemicals program

EDF report on HPV Challenge reveals missed deadlines, data quality concerns

Report date: July 2007
Page last updated: June 2015

Environmental Defense’s report, High Hopes, Low Marks: A Final Report Card on the High Production Volume Chemical Challenge [PDF], documented the shortcomings of the voluntary federal HPV program in 2007—more than a year and a half after it was supposed to be completed. By that time companies had yet to provide much of the promised data and the government faced big hurdles in filling remaining data gaps and addressing data quality concerns.

When it launched the HPV Challenge in 1998, the U.S. Environmental Protection Agency (EPA) acknowledged there were huge gaps in publicly available hazard data even for HPV chemicals (those produced in or imported into the U.S. in amounts equal to or exceeding one million pounds annually). Its aim was to voluntarily enlist manufacturers of HPV chemicals to develop and make publicly available a “base set” of screening-level hazard information on their chemicals.

Six report card metrics

Because the Challenge was voluntary, it sidestepped the significant legal burdens EPA must meet in order to compel testing of chemicals. By the same token, however, EPA also had limited recourse to ensure full participation by manufacturers or the timely submission and high quality of hazard data sets for HPV chemicals. Our report assessed both the chemical industry’s and EPA’s performance under the HPV Challenge, on each of six “metrics.” These measure the extent to which:

manufacturers sponsored their HPV chemicals;
program commitments (initial and final submissions) were met;
EPA has compelled information development for unsponsored HPV chemicals;
initial submissions were reviewed by EPA;
information submitted by sponsors was complete and of high quality; and
submitted information was made readily publicly accessible and usable.

Industry, EPA barely pass

Based on grades assigned on the individual metrics, the chemical industry earned an overall grade of D and EPA an overall grade of C minus.

The report notes that the Challenge was successful at developing and making public basic hazard information for more chemicals in much less time than prior efforts. However, the program’s serious shortcomings offer important “lessons learned” that are relevant both in recognizing the limitations of voluntary environmental initiatives, and in designing and executing them where they are used.