Part 1: Introduction and Purpose

The Sierra Club Toxic Chemicals Policy supplements its Environmentally Hazardous
Substances Policy. Its purpose is to assist members and staff in identifying and
controlling the unsafe and preventable impact of toxic chemical exposures on human
health and the environment.

It is based on the Sierra Club policy on the Precautionary Principle:

‘When an activity potentially threatens human health or the environment, the
proponent of the activity, rather than the public, should bear the burden of proof
as to the harmlessness of the activity. Where there are threats of serious or
irreversible damage, lack of full scientific certainty shall not be used as a reason
for postponing measures to prevent environmental degradation.’

Part 2: STATEMENT OF POLICY

Sierra Club supports:

Equity: Laws that protect the most vulnerable, people in low-income communities,
minorities, children, and prospective parents from toxic exposures.

Safer Alternatives: If they can be proven to be safer, alternative chemicals should be
substituted for the use of toxic chemicals for solving problems or producing energy or
products. This avoids the hazards associated with their use.

Stringent Testing of Chemicals in Use: Chemicals suspected of having adverse impacts
on the environment or human health must be evaluated for acute and chronic effects on
organisms representative of those potentially impacted. The release into the
environment of new or previously unrecognized toxic materials, such as nanoparticles,
must be restricted and carefully monitored until safe methods of use and disposal can
be documented, implemented, monitored, and restricted if necessary.

Testing of New Chemicals: No chemical substances should be introduced into use
without undergoing thorough environmental and health hazard evaluations for acute,
chronic, developmental, and other potential impacts. New toxicity testing methods
should be supported, but they must be capable of addressing all potential impacts,
including those that might be passed on to future generations for acute, chronic,
developmental, and other risks.

Updating Standards: Regulatory standards for limiting exposures to toxic chemicals
should be updated consistent with the latest science.

Bans and Phase Outs: Chemicals which cannot be proven safe should be banned or
phased out in a timely way.

Monitoring and Reporting to the Public:  Without regard to the origin of toxic chemicals,
entities responsible for managing potential exposures must carefully monitor their use,
immediately and fully report unsafe exposures to the public, and pursue additional
interim protective measures as warranted. This communication needs to be made in
ways that will be understood not only by scientists, physicians, and the regulatory 
community, but by all potentially affected individuals.

Part 3. Implementation:

Sierra Club members and staff are encouraged to take action to prevent, reduce, or
remedy the adverse effects that can result from exposures to toxic chemical substances
that are naturally occurring, human-made, or produced from naturally-occurring
biological processes. They should take a proactive role and assist regulatory agencies
in developing protective regulations, and they should advocate for interim protective
measures that will prevent toxic exposures or limit them to levels low enough that
adverse impacts will not occur.

Sierra Club members and staff are encouraged to develop and circulate accurate
scientific information and educational tools and make them widely accessible. Public
understanding of environmental problems can help protect the environment and human
health from the adverse impacts of hazardous substances. Increased public
understanding can help activists recruit and empower others in protecting the air, water,
land, communities, at-risk populations, and entire ecosystems.

Sierra Club members are encouraged to work with other organizations to investigate
and evaluate risks posed by toxic chemicals, inform others about them, and call for
interim protective measures if necessary. Citizen activists can call for studies, evaluate
the results of studies and impacts of exposure levels, and work with regulatory agencies
to establish and adopt these protective exposure levels. When federal or state agencies
send out draft regulations for public review, it is important that the Sierra Club and
individuals to submit comments. When new regulations are adopted, they should be
monitored to assure timely enforcement of more protective limits when needed.

Sierra Club members, staff and scientists are encouraged to monitor and officially
comment on the work of EPA and other government agencies, to serve on state and
federal advisory committees and to promote the adoption of legally enforceable
exposure levels that will protect the environment and the vulnerable populations within
it. If protective levels for a toxic chemical are not established, actions should be taken
to stop the production, use and disposal of the substance until such time as protective
measures are determined. These protective actions apply to actions taken pursuant to
other Sierra Club policies related to hazardous substances

http://www.sierraclub.org/policy/pollution-waste-management.

The Sierra Club Board tasks the Toxics Team with monitoring the latest science on
exposures to environmentally hazardous substances and recommending for approval
by the Vice President for Conservation updates to Sierra Club-supported limits to
exposure where warranted.

Part 4: Background Information for Protecting People and the Environment from
Toxic Chemical Exposures

Toxic chemicals may: 
(a) persist in the environment, become widespread and/or tend to become concentrated in living organisms,
(b) by their effect on biological or environmental processes, present an acute, chronic, developmental or 
other hazard to living organisms including human beings, and/or 
(c) combine, act synergistically, or break down in the environment to create substances that meet the above criteria.

Each chemical may have different |adverse effects on different organisms. For many
higher life forms, including humans, toxic effects may vary greatly depending upon the
route of exposure (air, water, dust, foods, household products), route of entry
(inhalation, ingestion, dermal contact), concentration, bioavailability, whether the
exposure is chronic or acute, and whether the exposure occurs to a parent or grandparent, during gestation, or during childhood, adolescence or adulthood.

In addition, in many cases, some toxic effects are not yet known or fully studied.
Human-made toxic chemicals. No chemical substances should be introduced into use
without undergoing thorough environmental and health hazard evaluations for all
potential impacts. New EPA and NIEHS toxicity testing methods should be supported
but it must be assured that they are capable of addressing all potential impacts
including those that might be passed on to future generations.

Toxic chemicals created through biological processes affected by human
activities: Some human activities have promoted the generation of unnatural and toxic
levels of biologically-produced toxins (e.g. cyanotoxins, mycotoxins). Causes of these
problems include inadequate treatment of wastewater, overuse or poorly targeted use of
fertilizer, global climate change, and, in the case of toxic mold, flood damage to
buildings. Activities leading to the generation of biologically created hazardous
substances should be evaluated and modified with a goal of reducing or eliminating
these threats.

Naturally-occurring toxic chemicals that may have adverse effects on living
systems: Use, concentration and dispersal of compounds and elements must be strictly
controlled to prevent adverse effects on human health and the environment. To prevent
exposures to natural toxic chemicals human activities must be more closely regulated
and in some cases stopped. For example, coal burning and the use of lead pipes for
distributing drinking water, should be phased out as soon as possible. 

Original policy posted at 

https://www.sierraclub.org/sites/www.sierraclub.org/files/2022-10/ToxicsChemicalsPolicy.pdf