50 



CAP (approximately 1,300 notices were received prior to the CAP, 1977-1991). 

 Through a "triage"-type review system, which highhghts the most serious risk con- 

 cerns among the reported information, we are able to process and evaluate about 

 4,000 submissions annually. While it is a challenge to screen the data, we believe 

 the CAP program will give us and the public a much better picture of the toxicity 

 of existing chemicals. We have much follow-up work to do on the 8(e) CAP program 

 to ensure that there is appropriate enforcement follow-up where companies did not 

 participate voluntarily. 



The risk management process for existing chemicals allows us to consider possible 

 action by other Federal agencies. Under TSCA Section 9 there is a formal regulatory 

 procedure for referring EPA's chemical risk determinations to other agencies for 

 consideration that has not always been very effective. We have found that coordina- 

 tion efforts are more effective. For occupational health issues, we developed a forum 

 to bring together senior officials from the Occupational Safety and Health Adminis- 

 tration (OSHA), the National Institute of Occupational Safety and Health (NIOSH), 

 EPA, and the Mine Safety and Health Administration (MSHA), called the ONE 

 (OSHA, NIOSH, EPA) committee. We helped establish a similar forum for inter- 

 agency cooperation between EPA and the Consumer Product Safety Commission 

 (CPSC). These fora provide a way to exchange information and identify possible risk 

 reduction strategies and opportunities for regulatory coordination for chemicals of 

 mutual concern. 



In short, the existing chemicals program of the nineties is a more productive and 

 more flexible program than its predecessor. Its mission has expanded to incorporate 

 pollution prevention as an integral part of program activities. Today's existing 

 chemicals program can accommodate a far broader range of initiatives and effec- 

 tively address a far greater number of chemicals than ever before. Development of 

 the use cluster approach has allowed us to address large numbers of chemicals in 

 a systematic way aimed at maximizing risk reduction and preventing pollution. The 

 availability of TRI data has made it possible for us to focus in on facilities with 

 large releases of certain chemicals. Programs to strengthen our TSCA-mandated in- 

 formation-gathering role, such as the 8(e) CAP program, have improved our knowl- 

 edge of— and therefore our ability to address — chemical toxicity and risk. Activities 

 like these are representative of the new directions the program has taken and is 

 continuing to take. Reducing risk from existing chemicals continues to be at the core 

 of the program, we now see preventing pollution as the central strategy for achiev- 

 ing that objective. Like our mission, the tools and strategies today's program is de- 

 veloping and using go significantly beyond what TSCA explicitly requires. 



New Chemicals Program 



In addition to the existing chemicals program, TSCA created a new chemicals pro- 

 gram. Section 5 of TSCA requires that anyone who intends to manufacture or im- 

 port a new chemical substance in the United States notify EPA 90 days before com- 

 mencing that activity. We are proud of our efforts in the new chemicals program 

 for two reasons: First, the program has been tremendously productive over the years 

 in reviewing thousands of new chemical substances. Second, by evaluating risks and 

 making decisions before a substance enters the marketplace, the program offers per- 

 haps the most cost-effective means of pollution prevention under TSCA. We believe 

 the program has been extremely successful in keeping harmful substances out of 

 commerce. 



The Government's new chemicals program is unique in that it requires review of 

 chemicals prior to manufacture rather than prior to marketing as in most other 

 countries with such systems. Since 1979, the new chemicals program has reviewed 

 over 24,000 new substances, including some 19,000 premanufacture notices (PMNs) 

 and over 5,000 low-volume, test-market, and polymer exemptions. Meeting the 90- 

 day (or shorter) review period for this high volume of submissions — over 2,000 noti- 

 fications annually— is a continuous challenge. Of the chemicals for which PMNs are 

 submitted, however, only about half make it to the marketplace and only a fraction 

 of these appear to be produced at levels above 10,000 pounds per year. EPA has 

 found reason to take action on about 5 percent of the PMNs submitted for review; 



