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the IEEE Committee on Environment, Health and Safety where 

 I'm responsible for creating and coordinating the position of the 

 IEEE on issues involving technology and environment. 



Mr. Chairman, I particularly want to commend you for seeking 

 testimony from a representative of the chemical user community. 

 We frequently feel a little bit left out of TSCA deliberations even 

 when they have some impact on us. 



I would like to begin by discussing the dramatically different way 

 modem manufacturing firms are looking at materials, which I 

 think may have some significant implications for TSCA. Two basic 

 trends have fundamentally changed the way that we must manage 

 materials: 



The first is that market forces have caused us to rely ever more 

 heavily on materials, science and technology for our competitive 

 edge. Products must be designed to be lighter and more energy effi- 

 cient while providing ever increasing functionality to the customer. 

 Additionally, what we call "time-to-market" has become critical, 

 sometimes even more so than our costs. Add in more efficient man- 

 ufacturing structures such as "just-in-time" operations, a material's 

 choice and management become critical determinants of competi- 

 tive success. Moreover, the system becomes much more delicately 

 balanced so that any disruption in material supply can shut down 

 the manufacturing system. So materials issues have become more 

 important for that reason. 



The second trend, however, is why we are here today. Eighteen 

 years ago when TSCA was passed, our focal concern was on the 

 toxicity of specific materials. Since then, however, we have become 

 much more knowledgeable about environmental effects, about in- 

 dustrial effects on natural systems, and about the global impact of 

 5y2 billion human beings. 



Our major concerns now, as identified by the EPA Science Advi- 

 sory Board and other expert groups, include such complex phenom- 

 ena as global climate change, loss of biodiversity, ozone depletion, 

 and degradation of soil and water resources. This is leading to a 

 fundamental change in the way environmental impacts of mate- 

 rigds are being defined and managed around the world. It is now 

 apparent, for example, that it is necessary to look at materials 

 across their life cycle if their full environmental impacts are to be 

 understood and mitigated. You have to look not just at your manu- 

 facturing processes where you may incorporate materials into a 

 product, for example, but you also have to look at what environ- 

 mental impacts occur when the materials are mined or initially 

 produced, when they used in commerce and in products, and when 

 those products are dismantled and pieces of them recycled again. 

 If you focus on just one life cycle stage, you will frequently fail to 

 recognize more serious risks posed at other stages. 



Moreover, you can't just consider one dimension of a material's 

 impact on the environment. Consider CFCs, an ideal material from 

 a toxicity viewpoint, but they turned out to be ozone depleters — a 

 far more serious problem. So at AT&T we replaced the CFCs used 

 in manufacturing. Sometimes we had to use toxic materials such 

 as chlorine gas to do so, although we obviously used highly engi- 

 neered and redundant systems when we did. 



