46 



Agency to high release chemicals that may need more study. And TSCA section 8 

 can be used to get additional information not covered by TRI. 



TSCA should also be used more effectively with other EPA statutes such as the 

 Clean Air and Clean Water Acts as a way to deal with an entire industrial facility 

 at one time. The Amoco Yorktown Refinery experiment points out that "whole facil- 

 ity" regulation can be much more cost effective that pipe-by-pipe solutions. 



Fixing even a few of these problems would be a tall order for any subcommittee. 

 Mr. Chairman, I'd be pleased to join you in trying. 



Statement of Lynn R. Goldman, Assistant Administrator, Office of Preven- 

 tion, Pesticides and Toxic Substances, Environmental Protection Agency 



Mr. Chairman and distinguished members of the subcommittee, I am Lynn Gold- 

 man, Assistant Administrator for the Office of Prevention, Pesticides and Toxic Sub- 

 stances (OPPTS) of the U.S. Environmental Protection Agency (EPA). I welcome the 

 opportunity to talk to you today about the Toxic Substances Control Act (TSCA). 



When TSCA was passed in 1976, there were a great many expectations about the 

 statute. It offered a promising mechanism to improve our understanding of chemical 

 risks and address these risks in a comprehensive multi-media framework. But, for 

 a variety of reasons, many believe TSCA has not been able to fully live up to these 

 expectations. It is ironic, then, that TSCA has not been the subject of significant 

 legislative action since its passage. In fact, TSCA is probably the EPA statute that 

 has seen the least change in the last 20 years. 



Since TSCA has not attracted the level of Congressional interest over the years 

 that it warrants, we are, encouraged by your interest in TSCA and in making it 

 a more effective and current statute. Your effort. Senator, is timely, especially now 

 that our work takes place in a world with a much broader environmental ethic but 

 a Federal government that faces more limits in its capacity to respond to the large 

 number of public concerns. 



Today, I will go through some of our lessons learned over the last 18 years and 

 discuss some of our accomplishments. From there, I will move to a discussion of our 

 vision for a successful toxics program, one that incorporates pollution prevention 

 and right to know concepts. These two concepts are the basis for several key issues 

 that I will lay out for your consideration as you consider legislative changes. 



I. accomplishments and lessons learned 



The Office of Pollution Prevention and Toxics (OPPT) within OPPTS is respon- 

 sible for implementing TSCA. TSCA has four general goals: (1) to gather informa- 

 tion on chemicals produced and circulated in commerce; (2) to identify and require 

 further testing of chemicals that may present risks; (3) to screen new chemicals that 

 have proven or may prove to present a risk; and (4) to control the production and 

 commercial distribution of chemicals proven to present a risk. To implement TSCA, 

 OPPT has established three areas of concentration: chemical testing, existing chemi- 

 cals, and new chemicals. Each focuses on reducing potential health and environ- 

 mental risks posed by chemicfds. 



Chemical Testing 



The Chemical Testing Program was established to carry out the policy expressed 

 in § 2 of TSCA that adequate data should be developed with respect to the health 

 and environmental effects of chemical substances and that the development of these 

 data should be the responsibility of chemical manufacturers and processors. — Since 

 the enactment of TSCA, OPPT and the Interagency Testing Committee (ITC) have 

 reviewed about 50,000 of the 70,000 chemicals Usted on the TSCA Chemical Sub- 

 stances Inventory to determine testing needs. In recent years, the ITC has con- 

 centrated on identifying and designating chemicals for action under TSCA §4 to 

 meet specific data needs of the agencies represented on the ITC. 



As a direct result of years of chemical screening efforts, OPPT has determined 

 that its efforts to identify candidates for testing or risk assessment should focus pri- 

 marily on the approximately 16,000 non-polymeric TSCA Inventory chemicals tJiat 



