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cated in the way in which we scope environmental protection. I 

 think we are truly in an era of pollution prevention, of integrated 

 pollution and toxics management, and the development of more in- 

 novative and voluntary coordinated approaches to controlling the 

 health and environmental risks of toxic chemicals. 



It is, therefore, necessary I think for us to re-evaluate the role 

 of a statute like TSCA in providing the kind of integrated analysis 

 and action-oriented mandates toward controlling and addressing 

 problems that may arise throughout the entire life cycle of chemi- 

 cal use from production through disposal. In reauthorizing TSCA, 

 Congress could take a critically important opportunity to incor- 

 porate pollution prevention precepts and to give the agency the 

 tools it could use to act upon these precepts. 



Now, my own involvement with TSCA goes back over 10 years 

 to the working out of consensus rules to reduce risks of PCBs. In 

 that process, I've become convinced that there is much common 

 ground among industry, government, and environmentalists in 

 terms of purpose and commitment to achieving real progress in the 

 prudent management of new and existing chemicals. I've also 

 worked with exceptionally skilled and dedicated scientists, ana- 

 lysts, and lawyers in the TSCA program at the EPA over these 

 years. 



However, despite this commonality of purpose and despite the 

 significant talent pool that has been devoted from the private and 

 public sector to this purpose, the history of TSCA implementation 

 is one of enormous frustration, and I think it is important for us 

 to examine how this has arisen. 



I would like to address in detail, alternative approaches to the 

 major areas of TSCA responsibility, and that is the identification 

 and development of action to address significant risks of existing 

 chemicals and the insurance of adequate information upon which 

 to base rational judgments for the deployment of new chemicals 

 into our market place. 



The intent of TSCA under its existing chemicals power was to 

 provide the EPA with the power to gather information related to 

 both exposures and hazard upon which to determine the necessity 

 to undertake risk reduction actions of a broad nature, including re- 

 ducing risks in the occupational setting. And that's why the 

 premanufacture provisions were important. It was envisioned in 

 the 1970s that TSCA could encourage a national program of ration- 

 al and prioritized chemical testing combined with an effective sur- 

 veillance system which accounted for information on both expo- 

 sures and adverse effects. Neither of those programs have been set 

 in place. Neither the testing nor the regulatory provisions have 

 been utilized to any significant extent. Testing of existing chemi- 

 cals, as you've already heard, has been sparse indeed with very few 

 test rules issued and those issued immediately challenged. 



But of even greater concern to us is the fact that the EPA has 

 never linked the programs in its Office of Research and Develop- 

 ment to its TSCA responsibilities nor has there been an effective 

 utilization through the interagency testing committee of the re- 

 sources of the National Institutes of Health in order to conduct and 

 utilize research directed toward the development and validation of 



