41 



Mr. CONDRAY. Monsanto is a manufacturer of some agricultural 

 products, and so we have some experience with FIFRA, which has 

 the burden of proof on the manufacturer to get a material through 

 the FIFRA registration process. Our experience would say that it 

 takes 7 years from the time that we make our first initial submis- 

 sion to the EPA until we get approval of a FIFRA registration for 

 one of our agricultural chemical products. 



Senator Reid. But isn't that a problem with the government in 

 that they're understaffed? 



Mr. CoNDRAY. I don't think so. I think we must prove the mate- 

 rial is safe. This is a very difficult scenario. So part of that is trying 

 to make sure that every question that can be asked by government 

 is addressed and addressed with data and information, and that is 

 just the way that the process works. So if that same process were 

 applied to the industrial chemical sector, we would see an enor- 

 mous erosion of new chemical innovation. New chemicals coming 

 down the road cannot carry that economic burden of, A, 7 years of 

 development, and, B, a toxicity testing cost of up to $2 million, es- 

 pecially at the premanufacturing stage. Before you've actually even 

 got the customers lined up to have that burden placed on a new 

 chemical, would seriously erode the ability to bring new chemicals 

 to market. 



Dr. Allenby. I guess, Mr. Chairman, I agree depending on how 

 it is carried out. What I mean by that is I think you also need to 

 look at what you're replacing as you bring out the new materials. 

 One of the things we have found is that in general — and I have to 

 admit much of this is not because of environmental planning, but 

 is fortunate happenstance — we're finding that our new products 

 overall in the electronics industry are more energy efficient, more 

 dematerialized, and provide more function than the ones they re- 

 placed. I think that the trick is in how we define what is environ- 

 mentally preferable, what is safe. Do we define safety just in terms 

 of acute toxicity for human beings, or does it include aquatic tox- 

 icity as well. Does it include contributions to global climate change? 

 We need to understand what environmental impact it is that we're 

 addressing in the regulatory program. If we had had to move away 

 from some of the uses of CFCs without being able to use chlorine 

 gas in closed systems, it would have been technologically very, very 

 difficult. 



So the question would probably be how can we put such a burden 

 on manufacturers while retaining the ability to evolve environ- 

 mentally preferable technologies and technological uses? If it is 

 done in a way which reflects the complexity of the environmental 

 perturbations that we're trying to manage, I think it's a reasonable 

 approach. My concern arises when we link it to only one end point, 

 which means that we optimize on that single end point without 

 considering the other range of environmental impacts. 



Senator Reid. How would both of you rate TSCA, as a success 

 or a failure? 



Dr. Allenby. I think all of our environmental statutes when 

 they were first contemplated grew out of an implicit mind set 

 which focused on specific effects, specific waste dumps, specific air 

 sheds, specific rivers, and in the case of TSCA, specific chemicals. 



