39 



cal program, and I think I heard some of the previous speakers 

 going both ways, some saying that they should be one in the same 

 in terms of regulatory management and others saying that they ba- 

 sically are different. And I fall into the latter case, saying that they 

 should be dealt with differently. 



New chemicals and existing chemicals, as you pointed out. Sen- 

 ator Reid, carry very, very different sorts of economic burdens with 

 them. Existing chemicals are in place, they're part of the economic 

 structure, they have a variety of uses, and are quite different from 

 new chemicals that are just coming out of the research laboratory, 

 with uses that aren't well established with markets that aren't well 

 established, and so forth. 



In the new chemical area, I think that TSCA has worked reason- 

 ably well, and as a company that has submitted premanufacturing 

 notices, I can assure you that the EPA is not an agency that is just 

 falling back and letting all the PMNs going through without appro- 

 priate challenge. They do have in place, as Dr. Goldman suggested, 

 a structure activity approach that uses the skills of the staff at the 

 EPA to look into the chemistry and understand the various poten- 

 tial hazard aspects. And SAR, structure activity, cuts both ways — 

 it can both let a chemical go through the process because it's a low 

 risk chemical: It's either very similar to a material that has low 

 toxicity, or low environmental effects, or whatever. Or, it (SAR) can 

 go the other way — it can be a family of chemistry that is a con- 

 cerned family. Let me assure you that if it's a concerned family, the 

 EPA immediately takes then a worst case scenario and says, well, 

 this could be a hazard, it could have aquatic effects. Therefore, if 

 there are going to be releases to water, you must generate data to 

 show that those releases are not harmful. 



There are provisions in there to catch, if you will, the problem- 

 atic materials. There are likewise provisions to let the low risk ma- 

 terials flow through the process relatively unscathed. 



So I think that the way the system is set up in the new chemical 

 area is working reasonable well. There is burden on industry, as 

 I said. If you're in a family of chemistry that's problematic, that 

 data needs to be brought to the table. In fact, there is a policy that 

 the EPA administers that tells you even the kind of volume trig- 

 gers and the kind of data that would flow with that sort of 

 premanufacturing notice. So it's not as though it's just a blank 

 check and no data goes in. It actually does go in with some surety. 



On the other side of the equation in the existing chemical area, 

 the problem that I see with that activity is that there has been dif- 

 ficulty in setting a systematic approach to weeding out the 16,000 

 chemicals that Dr. Goldman suggested, which ones really need ad- 

 ditional data, which ones really need to have assessment, and 

 which ones really need risk management or control. And that proc- 

 ess of screening and selecting is one that we've been dialoging with 

 the EPA at CMA now for a year or so on sajang that we need to 

 be looking at what are some common criteria. How do we take 

 16,000, apply our resources to the group of those chemicals that 

 really neea attention, and put the others on the shelf for future 

 evaluation? In other words, let's work on the ones that need the 

 priority attention. 



