latoiy negotiation process to include our various stakeholders in 

 the development of this new rule. 



In addition, we have worked with a variety of groups to advance 

 the design for environment ethic and the development and evo- 

 lution of technology and material choices and are incorporating this 

 approach into the review of new chemicals. 



In addition to these first two strategies, there are always be a 

 need for our third strategy — taking targeted action on certain pri- 

 ority areas. These projects now are focused on particular chemicals, 

 or, more recently, on clusters of chemicals that can be used to per- 

 form a particular task. The use cluster approach enables us to 

 identify those chemicals or categories of chemicals in combination 

 with technologies that represent a safer way of performing the es- 

 sential function in a cost-effective manner. 



Thus, for example, instead of just looking at a single chemical 

 that might be used as a paint stripper, we're now looking at a 

 number of chemical paint strippers to determine which materials 

 and processes are safer. 



As you know, Mr. Chairman, section 6 has not been the effective 

 tool for targeted action we once thought it could be. The U.S. Fifth 

 Circuit Court of Appeals decision to remand the 1989 asbestos ban 

 and phase out rule to EPA has several implications. 



First, section 6 actions that we initiate now will be far more re- 

 source intensive and take longer than had originally been envi- 

 sioned. 



But, second, the court's interpretation of least burdensome alter- 

 native would require us to consider future action and a hierarchical 

 approach that defines end of the pipe solutions as less burdensome 

 than pollution prevention solutions. We feel that this conflicts with 

 the hierarchical approach set forward in the Pollution Prevention 

 Act, which as you might expect makes reduction or elimination of 

 toxics at the source the ultimate goal. In addition, we believe that 

 a pollution prevention approach is often the most cost-effective ap- 

 proach. 



Finally, the EPA's ability to take regulatory action under section 

 6 is an important part of the incentive structure that we have in 

 place for encouraging voluntary actions. 



In closing, I want to thank the committee and Chairman Reid for 

 your interest in a successful toxics program. Hopefully, this will be 

 a start of a productive dialogue that will help us accomplish that 

 objective. 



Thank you. 



Senator Reid. Dr. Goldman, I appreciate your being here today. 

 It's important to state on the record the fact that you re a medical 

 doctor. I think it's assumed that government employees are faceless 

 bureaucrats who would never leave their big office buildings, but 

 the fact of the matter is there are many people like you, and I 

 think it speaks well of government that there are still people will- 

 ing to put up with what bureaucrats have to put up with in this 

 time of stringent cost controls. I am grateful to you personally that 

 you're willing to take this job. 



I have a number of questions. With a large number of chemicals, 

 the scientific complexities of testing and review, and the limits of 

 governmental resources, I'm interested in seeing that industry 



