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the chemical industry researches and develops new chemicals, how 

 we operate our facilities, how we distribute goods, how we deal 

 with our customers, how we manage wastes, and how we interact 

 with the public. 



Today risk management and pollution prevention are firmly em- 

 bedded in the chemical industry. Our commitment to risk manage- 

 ment is evidenced by our own product stewardship initiative, which 

 is in its second year of implementation. Our commitment to pollu- 

 tion prevention is also clear. Over the past 6 years, CMA compa- 

 nies have reduced emissions to the environment by 38 percent. 

 Today our economy is woven into the fabric of a global economy 

 like never before. Chemical regulation today has more of a multi- 

 plier effect influencing other industries around the globe that use 

 chemicals as basic building blocks for virtually every product in 

 commerce. 



Today the chemical industry is a global industry in which compa- 

 nies are both multi-national and multi-cultural in their outlook. 

 Corporations are expected to be more open with the public, more 

 responsive to concerns about their businesses, their facilities, their 

 operations, and their plans for future development. We view our- 

 selves not just as chemical manufacturers, but as product stewards. 

 And it's a responsibility that we in the chemical industry take very 

 seriously. 



Mr. Chairman, we think it's very important that we consider this 

 information. Doing so gives us some insights into how government 

 should approach chemical regulation. We see a need for a flexible 

 approach to chemical regulation, one that considers the full range 

 of management options from labeling, product information, use and 

 disposal restrictions, all the way up to severe actions such as a ban 

 in the advent of an unreasonable risk. This approach should con- 

 sider not only the risk, but also the benefits that chemicals provide. 



We see a need for a multi-media perspective. The government 

 should have the authority to regulate chemicals to prevent or liniit 

 exposure from all pathways. We see an opportunity to create initia- 

 tives for risk reduction by reviewing new chemicals and having the 

 authority to take action before they enter commerce. The govern- 

 ment can ensure that appropriate risk management practices are 

 put in place. 



We see the value of a comparative risk approach so that we, as 

 a society, can focus first on those applications of chemicals that 

 pose the greatest risk. This is especially important in an era of lim- 

 ited resources where it is more important than ever to achieve 

 maximum return for our investments. To us, maintaining a multi- 

 media perspective, providing incentives for risk reduction, setting 

 risk-based priorities, and adopting a flexible program is the right 

 approach for regulating chemicals in commerce. And this is the ap- 

 proach that Congress built into TSCA. 



I am not suggesting there aren't real issues in TSCA that need 

 to be addressed — certainly, there are. You raised some of these is- 

 sues in your letter to us inviting us to testify, problems like the 

 need for additional information on chemicals that can be used in 

 certain applications, problems like too many improper claims of 

 confidential business information. These aren't easy problems to 



