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Senator Reid. Why shouldn't we have the same type of program 

 for the EPA and new chemicals? 



Dr. Goldman. I think that one thing I would be concerned about 

 is that if we treated every chemical as though it had the same ex- 

 posure potential as a drug, that then we would set in place a bias 

 toward the chemicals that are on the existing chemicals list, and 

 we would create 



Senator Reid. Do you mean a positive bias? 



Dr. Goldman. A positive bias for the existing chemicals or a dis- 

 incentive for companies to do research and development to develop 

 new safer chemicals. I think it is true 



Senator Reid. Dr. Goldman, if I could just interrupt there. 



Dr. Goldman. Sure. 



Senator Reid. If they're doing research and development for new 

 chemicals — and I think that says it all — shouldn't they have to 

 share that information initially with the EPA rather than the EPA 

 having the burden at a later time to show that the EPA believes 

 these chemicals are unsafe? 



Dr. Goldman. Absolutely, but I also think that the quantity of 

 information that we should be getting from them should be some- 

 what proportional to the likelihood that the chemical that they're 

 producing will be pharmacologically active in people. 



Now what the FDA is dealing with is by definition are materials 

 that are pharmacologically active, and they're always dealing with 

 materials that humans will be exposed to because the/re adminis- 

 tered to people. 



A second level of review might be more like what we deal with 

 in the pesticide program where many of those substances are used 

 because they are pharmacologically active. They're used because 

 they are neurotoxic and because they kill organisms, and I think 

 that it is appropriate that we have a more extensive review and 

 testing program for those chemicEds than for some of the TSCA 

 chemicals. 



I think with the TSCA chemicals, we have to find ways to make 

 cuts and be selective. Certainly, the polymers are not going to be 

 as active as, say, solvents. 



Senator Reid. It seems to me. Dr. Groldman, that if in fact we're 

 under the first category you describe, it would be very easy for the 

 chemical manufacturer to say to the EPA, "This chemical is not 

 going to be come into contact with human beings ever. Therefore, 

 this standard is significantly less." 



The burden should be on them to show that, not us. 



Dr. GrOLDMAN. Absolutely, I think the burden should be on them 

 to show that. 



Senator Reid. And then if it's in the second category, the same 

 principle applies. So I think it's something we need to take a real 

 close look at, and I would ask also that your agency help my staff 

 do that. 



Dr. Goldman. Well, one of the things that I believe is that the 

 criteria has to be very clear so that we're not bogged down in litiga- 

 tion every time we try to issue a test rule. We need clear criteria. 



Senator Reid. Now we're talking now about new chemicals? 



Dr. Goldman. Both new and existing chemicals. 



Senator Reid. Pardon me? 



