28 



and that's been the standard that we've been working under all 

 this time. 



Dr. SiLBERGELD. I think that says something about why we're 

 where we are all this time. Certainly, in terms of magnitude of ex- 

 posure and identified problems, the existing chemicals are the larg- 

 est concern from the public health perspective. We need only think 

 about substances such as glycol ethers, lead, and many of the sol- 

 vents to remember that. And it's not always related to production 

 volume, as I would remind Dr. Goldman in considering dioxins. It 

 may not even be intentional production which gives rise to prob- 

 lems of legitimate concern, 



I would urge the Congress to consider some of the more innova- 

 tive approaches to prioritization that have been experimented with 

 by other countries and by the OECD so that we don't get locked 

 into what we could called the "GRAS list approach" to existing 

 chemicals. That is, because it's out there, therefore, we concede 

 that it's generally recognized as safe and we will move on to other 

 problems. 



At any point that we introduce a new concept in public health, 

 we are always confronted with the existing world and the burden 

 of making sense of that imbalance between those new opportunities 

 that present themselves for increased vigilance and more efficient 

 action and the enormous burden of what has happened without any 

 particular oversight or efficiency, but we cannot overlook the fact 

 that it's in that disordered world of the existing chemicals that 

 probably the greatest ongoing present risks to human health and 

 the environment reside. 



Senator Reid. I have no problem with that statement. Mine is 

 one of practicality though. 



How are we going to get a handle over those that are already in 

 the market? Would we all agree that for the new ones it should be 

 relatively easy compared to the old ones because we could just shift 

 the burden and say, "Manufacturer, if we're going to be using new 

 compounds, show us that they're okay." It seems to me the new 

 ones would be an easier problem to handle. 



Dr. Mum. Why isn't it possible. Senator, to shift the burden with 

 respect to existing chemicals so that increasingly the people who 

 determine the uses of these materials and specific applications 

 have a greater responsibility for making sure that the^re environ- 

 mentally sound? 



We've got large problems with persistent bio-accumulative toxic 

 chemicals in the Great Lakes, for example, and I could see us de- 

 veloping a norm that one should not use such materials, particu- 

 larly in dispersive applications. I hope and expect that such a norm 

 could be adopted and applied to our industry so that, we can get 

 on with tackling this problem. If we have to wait for the EPA to 

 take up each of these chemicals individually and go through testing 

 to find out whether each chemical does or does not pose unreason- 

 able risk, then I really fear for the Great Lakes. The larger prob- 

 lems are with the existing chemicals, and I hope, as as result of 

 TSCA's reauthorization, that the responsibilities for the manufac- 

 turers and producers to use chemicals appropriately would apply 

 not only to new chemicals but to existing ones as well. 



