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more effective and cost-effective test methods that could serve the 

 purposes of TSCA. 



The surveillance provisions of section 8 have been even less effec- 

 tive. The incentives for the private sector to report adverse effects 

 of its products are nonexistent. The EPA, moreover, has made no 

 use of any other existing surveillance systems such as the National 

 Human Adipose Tissue Survey or the National Center for Health 

 Statistics' Nationsd Health and Nutrition Examination Survey, 

 both of which actually report data on the presence of some chemi- 

 cals in tissue samples taken from the general U.S. population. 

 These data could be invaluable tools to focus our attention under 

 TSCA on chemicals to which individuals and populations are de- 

 monstrably being exposed. 



Only recently has there been an attempt through the initiatives 

 of the Agency for Toxic Substances and Diseases Registry to use 

 the powers of TSCA to fulfill critical data gaps that have been iden- 

 tified in the Super Fund Program. 



Now, the prospect of dealing rationally with the entirety of the 

 TSCA inventory — ^the 60,000 chemicals we've already talked 

 about — is certainly daunting, but it doesn't need to be paralyzing. 

 And here I would urge that the EPA bring home and Congress in- 

 sure the importation of our experience as productive members — 

 that is, government and industry — as productive members in the 

 Organization for Economic Cooperation and Development Chemi- 

 cals Program. The OECD over the past decade has adopted an in- 

 novative approach that we commend for your consideration in 

 TSCA reauthorization. 



The OECD approach, the Screening Information Data Set Pro- 

 gram, or SIDS program, neatly overcomes the paradox of the un- 

 known. In TSCA as in much public policy based upon toxicology, 

 we are often guilty of continuing to look at those chemicals about 

 which we already have sufficient information to consider them 

 highly suspect. I think the last 15 years investments in the assess- 

 ment and re-assessment of the risks of dioxin are a sad paradigm 

 of this way in which we've invested public and private resources. 

 We do not seem to be able to overcome this paradox and move to 

 the enormous universe of chemicals about which we know very lit- 

 tle. 



A prioritization rule which has been developed within the OECD 

 program has used production volume as the criterion for identifying 

 those chemicals about which it is incumbent to gather some mini- 

 mum data set. There was no argument about what types of infor- 

 mation are critical, but a screening information data set using vali- 

 dated replicable and highly cost-effective tests has been put in 

 place on a voluntary basis among the governments and industries 

 within the OECD countries. 



This SIDS project is clearly an evolving concept but one which 

 to date has shown great promise in allowing us to bootstrap our 

 way out of the paradox of dealing with what appears sometimes to 

 be an overwhelming burden of ignorance — that is, our lack of 

 knowledge of existing chemicals. 



With respect to new chemicals, we share with you a profound 

 disappointment in the inability of TSCA to establish a rational pre- 

 cautionary approach to the evaluation of new chemicals. TSCA 



