Is Regulating By Groups More Effective? Or Not?

Abstract

Regulating by groups may be one of these concepts that initially sounded good but starts to fall apart under close scrutiny. We need to ensure that a cVOC Rule increases public health protection and does not imply more effective regulation that cannot be demonstrated. A group regulation should not be developed for the sake of regulating by groups.

Evaluation of Effects of Potential Group cVOC Regulations on Two Utilities

“…As with the first approach for establishing a group MCL, this approach may be challenging to implement in everyday practice. As Roberson (2013) described previously, this approach is complicated by a few of the individual compounds being considered, such as 1,2,3‐trichloropropane (TCP), that have substantially higher cancer slope factors than other compounds. If the cVOC regulation is developed around reducing total risk, it may be difficult to establish a total risk framework that is not a de facto TCP regulation.…”

Five Yards for Delay of Game

“…It's a good concept in theory. However, in practice, developing a group regulation has been much more challenging than anticipated (Roberson, 2013). The ongoing federal budget issues have likely contributed to the cVOC Rule being delayed into 2015 (and potentially even later).…”

Delays in the Regulatory Schedule From Budgets and Others

“…Regarding the cVOC Rule, nothing much new has happened with it other than it's still not completely clear which specific cVOCs are going to be included in the proposed rule in 2014. The cVOC Rule is turning out to be USEPA's first test in regulating by groups, and it's turned out to not be as simple as originally anticipated (Roberson, 2013). Previous research found several differences in physical and chemical characteristics for the cVOCs initially considered for this rule as well as the need for multiple analytical methods (Roth, 2012;Eaton, 2012).…”