Editors' Column Implementation of TSCA "Science can ultimately tell us whether a substance is toxic and the degree of exposure we can anticipate. B u t only a policy guided by ethics, judgment, and public understanding can tell us whether the benefits are worth the risks of exposures." These were the concluding remarks of Douglas M. Costle, administrator of the U.S. Environmental Protection Agency (EPA), at a recent symposium entitled "A New National Priority: Chemical Innovation with Chemical Legislation". This symposium was one of several concerned with public safety and toxic chemicals featured at t h e 174th National Meeting of the American Chemical Society in Chicago. Since passage of t h e new chemical legislation, numerous national forums as well as these ACS symposia have attracted large audiences. T h e large attendance, however, seems to be more indicative of the chemical industry's anxiety over t h e adverse effects of t h e new law than of anticipation of real answers.
by the Analytical Chemistry Division at the Chicago meeting, E. W. Bretthauer of E P A discussed this problem specifically with respect to trace metals in t h e bioenvironmental systems. He said t h a t the environmental surveillance of trace metals u p to now has been largely an after-the-fact approach. It is extremely difficult to relate the biological effects of long-term, low levels of toxic pollutants as t h e pollutants transcend the environmental pathways, i.e., air, land, water, and food. T o formulate a before-the-fact surveillance approach which can establish a definite relationship between the level of a toxic substance and its biological effect, an integrated monitoring system t h a t can determine t h e total exposure from the various pathways is needed. Also determination of total absorption and residual concentration in t h e entire biological system must be included in such a study. In this regard, he noted t h a t advances in analytical techniques in recent years have made it possible to detect
T h e impetus for these public discussions was the implementation of the Toxic Substances Control Act (TSCA), which became effective on 1 J a n u a r y 1977. As discussed earlier [Anal. Chem., 49, 247A (1977)], in essence t h e law directs E P A to take an inventory of all chemicals marketed in the U.S. prior to July 1977. T h e law also gives E P A the authority to require the manufacturer of new chemicals to furnish safety data 90 days before marketing to avoid the after-thefact approach of t h e past. Implementation of these provisions is forcing manufacturers to generate an enormous amount of data such as t h e name, chemical identity, proposed usage, amount of production, and especially the adverse effects on health and environment, exposure in the workplace, disposal practices, etc. Implicit in the authority given t o E P A is the availability of adequate methodologies for both testing and monitoring of these chemical substances. At a symposium sponsored
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a large number of trace metals in various media with detection limits which are more than adequate. However, in the case of determinations of trace and ultratrace levels of metals in cellular and subcellular components of the body, often suitable analytical methodologies are not available. Mr. Bretthauer further emphasized that the analytical chemist must not isolate him/herself in the laboratory but must become involved in interdisciplinary programs, especially at the planning stage. The analytical chemist is in a unique position to provide "detailed recommendations on the type and size of samples to be obtained, methods of sample preservation and preparation, and the methods of analysis. In recommending the method of analysis, he must consider the various available methods in terms of sensitivity, accuracy, selectivity, and cost-effectiveness. Finally, it is the prime responsibility of the analytical chemist to interpret the analytical data, provide qualifications with certain data if necessary, and to implement a quality assurance program to assess the validity of the data being provided." Mr. Bretthauer's final point to analytical chemists was to generate statistically valid data. This seems to be one of the major challenges to the analyst when dealing with environmental or biological samples. In addition to the problems inherent in the analysis of low levels of compounds, such an analyst must work with an extremely complex and variable matrix. This particular problem was previously addressed by R. O. Kagel of Dow Chemical at a meeting sponsored by the Manufacturing Chemists Association this past January. He advocated the use of the "10-10-10" principle, originally developed for the analysis of pesticide residues. Briefly, 10 determinations are made on a control sample, i.e. (in the residue studies), untreated crop soil or animal tissues, to determine interferences; 10 determinations are made on the control sample spiked with varying concentrations of the compound of interest to determine recoveries; finally, 10 determinations are carried out on different aliquots of the same sample to determine the precision of the procedure. The statistics of the analytical procedures can be verified by two or more independent laboratories. As adopted by the USDA and FDA, this procedure has worked well for the analysis of pesticide residues in animal tissues, plants, soil, and water; it should work equally well in the determination of environmental pollutants. Barbara Cassatt
