270 



ment to prevent unnecessary morbidity and mortality and the financial burden of 

 regulation and litigation. 



• Improving the science base for risk assessments by conducting studies of the 

 biologic mechanisms of toxicity and adding other important health end-points to 

 modern toxicologic studies. 



• Providing a scientific approach to addressing questions of environmental equity 

 and environmental justice by identifying the critical additional environmental con- 

 tributions to the burden of illness and disability in a Nation where as many as one 

 child in five lives in poverty. 



• Fulfilling a need for health professionals (physicians, nurses and other allied 

 health workers) and research scientists to pursue careers in environmental and oc- 

 cupational medicine, health and health sciences. 



We would be pleased to provide additional information. 



Prepared Statement of Chemical Manufacturers Association 



The Chemical Manufacturers Association (CMA) offers the following comments re- 

 garding the Department of the Environmental Act of 1993. 



CMA is a nonprofit trade association whose members represent more than 90 per- 

 cent of the productive capacity for basic industrial chemicals in the United States. 



CMA supports the idea of elevation of the Environmental Protection Agency 

 (EPA) to a cabinet level department as proposed in S. 171. Elevation of EPA to cabi- 

 net rank will demonstrate the commitment of this country to protect the environ- 

 ment, insure that our environmental policies are coordinated with other Federal 

 policies, and provide the secretary ministerial rank for international negotiations 

 and meetings. 



While some may see creation of a cabinet rank agency as simply a symbol, we 

 believe it offers a number of opportunities to improve the commitment to protect 

 the environment. Specificeilly we hope the department will take a leadership role in 

 insuring that sound, scientifically defensible steps are taken to protect the environ- 

 ment. Too often in the past this country has made environmental decisions based on 

 emotion. We must insure that all of our decisions are based on peer reviewed data 

 and reasonable predictions of the effects of an action as well as the impact of taking 

 no action. The department must set priorities b£ised upon overall risk to human 

 health and the environment and not be swayed by media attention to current issues 

 that are not of overall importance to the environment. 



The new department should assist the public in making informed decisions by 

 providing information on technical matters, such as risk analyses, and emission 

 data. The public needs to understand the numbers we bombard them with in the 

 context of the other decisions they face. 



T\tle I^Elevation of the EPA to Cabinet Rank 



Title I of S. 171 can provide most of these benefits, but in the process of establish- 

 ing the new Department, we should not create long term programs that could fur- 

 ther complicate the mission of the Department and use resources better saved for 

 existing programs. We recommend that the proposed functions of each new entity 

 be reviewed carefully against the present or potential functions of existing entities 

 to avoid duplication, overlap and unnecessary bureaucratic growth. Where existing 

 organizations can do the job, the creation of new organizations, redundant of exist- 

 ing organizations should be eliminated in whole or in part. 



We offer the following comments on Section 108 of Title I and Title II with a view 

 toward minimizing overlapping authorities, data collection efforts and regulations of 

 the various agencies with a role in environmental protection. 



Section 108 — Bureau of Environmental Statistics 



We endorse the idea of establishing a Bureau of Environmental Statistics to col- 

 lect and disseminate information about environmental quality. Compilation of this 

 information will assist the public in understanding the overall effectiveness of envi- 

 ronmental control measures. It will also help the government set priorities and 

 spend its resources on those issues that will result in the largest potential for im- 

 proving the quality of the environment. The simple act of compiling data from the 

 many different agency data collection efforts will be useful. 



While the new Bureau will be beneficial, we do not support any authority to 

 make any new data collection requirements. All authority to collect information 



