26 



Dr. Mum. I do think that the burden should shift, and I think 

 that use categories can fit into the amount of information that is 

 reasonable to develop. 



Senator Reid. Dr. Muir, explain once more how you disagree 

 with Dr. Silbergeld? 



Dr. MuiR. I think that, for example, a use which is proposed for 

 some type of closed-system, intermediate application may warrant 

 less testing than something that is proposed for widespread human 

 exposure 



Senator Reid. I personally don't disagree with that, but the bur- 

 den should still be, in my opinion, upon the manufacturer to show 

 to the EPA what in fact will be the use of that product. 



Dr. MuiR. No, I quite agree. I quite agree. I think that 



Senator Reid. But now that isn't the way it is. 



Dr. Muir. Oh, I agree with you, and my testimony indicates that 

 I think a greater burden should be on the part of people proposing 

 new chemicals to carry out a basic assessment. 



Senator Reid. Dr. Silbergeld? 



Dr. Silbergeld. I'm not sure if we disagree, Warren, or not, but 

 I think that there is some minimum data set that every new chemi- 

 cal must come into the agency for evaluation with. The stage at 

 which that comes, I think, is open to discussion in terms of effi- 

 ciency of process. But I don't think any chemical should be allowed 

 into the American environment, including the industrial environ- 

 ment, without some minimum set of data. 



Moreover, I believe that assertions related to exposure must be 

 backed up by a bearing of the burden by the party asserting to 

 monitor for such exposure. 



Senator Reid. I would like the record to reflect that we know of 

 the General Accounting Office and its long involvement in this 

 issue. Dr. Silbergeld, we know, is a scientist who's worked at the 

 National Institutes of Health and taught at the University of Mary- 

 land Medical School and Johns Hopkins. 



Dr. Muir, for the record, tell us about the Hampshire Research 

 Group. 



Dr. MuiR. We're a small environmental scientific and engineering 

 group located in Alexandria, Virginia. I founded it after I left public 

 service in 1981. We are a scientific and engineering computer-pro- 

 gramming organization that does most of its work for government 

 and environmental agencies, public interest organizations, sci- 

 entific and international organizations, around the world, trying to 

 bridge scientific and engineering issues for public policy and public 

 understanding. We have been heavily involved in issues of risk as- 

 sessment, pollution prevention, and the use of toxics data to pro- 

 mote environmental ends. We've done such things as produce the 

 EPA's Toxic Release Inventory reports, for example. 



Senator Reid. I appreciate that. I think it's important for the 

 record to reflect the work that has been done by your entity. 



Mr. Guerrero. Mr. Chairman, if I could just add one postscript 

 to this because I believe you started and prefaced your question 

 with some speculation as to whether there could be maybe a dif- 

 ferent standard for existing chemicals versus new ones 



Senator Reid. Yes, we didn't follow up on that. I appreciate that. 



