Table 1 Chemicals grouping methods available to regulatory agencies in the US and the EU
Agency | What was considered | Law | Legal requirement to group chemicals | Rationale for grouping | Grouping applied | Outcome | Reference |
|---|---|---|---|---|---|---|---|
US CPSC | Organohalogen flame retardants | Federal Hazardous Substances Act | No | Same function (suppress fire); common chemical structure or predictive biological activity | No | CPSC has yet to agree on NAS grouping proposal | NAS 2019 [4] |
US CPSC | Ortho-phthalates | Consumer Product Safety Improvement Act | Yes | Common adverse outcome due to anti-androgenic effects | Yes | Banned eight ortho-phthalates from children’s toys and articles | NAS 2008 [22] |
US EPA | Pesticides | Food Quality Protection Act | Yes | Same toxic effect caused by same molecular mechanism of action | Yes | Conducted cumulative risk assessment for five classes of pesticides: organophosphates, N-methyl carbamates, triazines, chloroacetanilides, pyrethrins/pyrethroids | EPA [8] |
US EPA | Industrial chemicals | Toxic Substances Control Act | No | Structural similarity; similar “physical, chemical, or biological properties;” similar use; similar exposure pathway | No | EPA has yet to identify classes | EPA [23] |
US FDA | Food additives | Food Drug and Cosmetic Act | Yes | Structurally or toxicologically related | Yes | Banned uses of long-chain PFAS in food packaging | FDA [24] |
US Washington State | Classes of chemicals in consumer products | Pollution Prevention for Healthy People and Puget Sound Act | Yes | Persistent, bioaccumulative and toxic or hazardous to children’s health | Yes | Regulates five classes of chemicals: PFAS, ortho-phthalates, OFR and other flame retardants identified in RCW 70.240.010, phenolic compounds, PCBs. | Department of Ecology [25] |
US Washington State | Per- and polyfluorinated alkyl substances (PFAS) | Packages containing metals | Yes | Persistent, bioaccumulative and toxic | Yes | PFAS banned from use in fiber-based products in contact with food | Department of Ecology [26] |
US State of Maine | Chemicals in food packaging and packaging components | Reduction in Toxic Packaging | Yes | Persistent, bioaccumulative and toxic; or hazardous to children’s health | Yes | Bans PFAS and ortho-phthalates | Department of Environmental Protection [27] |
US State of California | Chemicals in consumer products | Safer Consumer Products Regulations | No | Persistence | Yes | PFAS | Department of Toxic Substances Control [28] |
EU EFSA | Food flavouring substances | Flavouring substances | Yes | Structural similarity | Yes | Regulates flavors across 34 groups | |
EU EFSA | Pesticides | Pesticides | Yes | Common toxic effects | Yes | Cumulative risk assessment; identified two groups: affecting the nervous system and the thyroid system | EFSA [30] |
EU ECHA | Industrial chemicals | REACH | Yes | Structural similarity | Yes | Read-across | ECHA [30] |
Health Canada | Industrial chemicals | Yes | Structural similarity | Yes | Prioritization of nine groups: aromatic azo- and benzidine-based substances; substituted diphenylamines; cobalt-containing substances; methylenediphenyl diisocyanates and diamines (MDI/MDA); certain internationally classified substances with potential for exposure to individuals in Canada; selenium-containing substances; certain organic flame retardants; ortho-phthalates; and boron-containing substances. | Health Canada [31] |