The production and use of chemicals are increasing worldwide. As of January 2015, more than 84,000 chemical substances are on the Toxic Substances Control Act Inventory of Existing Chemical Substances and 500-‐1000 are added each year.1 Governments, organizations, committees, networks, scientists, and concerned individuals around the world are working toward toxic-‐free people and environments. With all the information that is available, it is widely recognized that there are data gaps with the risks that are generated by toxic chemicals that are being used in the products we use daily. While risks to the general public and other subpopulations may be addressed by other groups, NTTC’s purpose is to identify ways that toxic chemicals may be specifically impacting American Indian tribes, Alaska Natives, and Native Hawaiians, identified as “tribes” throughout this document. NTTC members are working with tribal representatives across the nation and OPPT to provide limited input on areas of concern for tribal communities that may influence OPPT’s risk assessment process for the TSCA Work Plan chemicals. It is critical that all EPA programs consider how chemicals are affecting tribal communities’ subsistence food and traditional activities, yet years of recommendations from National Tribal Councils, organizations, and researchers noted in Section 3 of this report have made little progress with incorporating tribal data into EPA’s risk assessment process. Additionally, tribes and other organizations have been requesting assistance to collect and incorporate tribal-‐specific data for over two decades. It is NTTC’s perception that EPA has not adequately considered tribal concerns regarding exposure to toxic chemicals. NTTC members and experts in the field of tribal exposure and risk assessment have summarized key findings and recommendations in Section 4 of this report. Based upon NTTC’s evaluation of TSCA and review of OPPT’s risk assessment process, NTTC concludes that tribal populations are unnecessarily left at significant risk. This report is intended to improve decision making by informing elected officials, representatives, tribal leadership, EPA regional administrators, national and regional tribal representatives of tribes’ unique exposures to toxics that are not considered in current TSCA risk assessments (or in risk assessments conducted under other statutes that serve in lieu of TSCA risk assessments), as well as help guide NTTC and OPPT in providing a framework for TSCA risk assessments and policy development that are more protective of tribal health and the natural resources that have sustained tribes for generations.
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