56 



limited resources more wisely. Thus it may be an appropriate time to consider 

 whether some parts of the statute might be simplified to make the program efficient 

 and focused on priority activities. 



CONCLUSION 



These new approaches to risk reduction and pollution prevention set ambitious 

 goals for our program. Progress to date is very encouraging, and the response from 

 interested parties has been tremendous. If we can continue to move this work for- 

 ward, we will play an important role in improving and protecting the environment. 



It is important to note that we do not view these new approaches of our toxics 

 program to be, in any way, incompatible with our chemical specific and core TSCA 

 work. These new approaches are based on the foundation of past and current chemi- 

 cal specific work. They are the inevitable outcome of the focus on pollution preven- 

 tion and the understanding of the need to involve as many others as possible in a 

 national program for toxics. 



Thank you for the opportunity to speak to the subcommittee on our accomplish- 

 ments with and lessons learned fi-om implementing TSCA. We look forward to work- 

 ing with the subcommittee as it considers the challenges of reauthorizing TSCA. 



FoLLOwup Questions for Dr. Lynn Goldman from Senator Reid 



General 



1. With the large number of chemicals, the scientific complexities of testing and 

 review, and the limits of governmental resources, I am interested in seeing that in- 

 dustry shoulders the principal responsibility for determining the health and envi- 

 ronmental effects of the chemicals they manufacture. What is your assessment of 

 the burden that industry has now, and do you have any opinion on whether indus- 

 try should bear a greater burden? 



2. TSCA takes a chemical by chemical approach. It assumes that EPA can, to one 

 extent or another, review these individual chemicals and regulate those with severe 

 risks. Did TSCA give EPA an impossible mission? Is chemical by chemical the 

 wrong approach to managing chemical risks? What are the alternatives? 



3. As you know, TSCA's focus has primarily been on chemical manufacturers and 

 processors. But you have talked about expanding this to encompass chemical users. 

 What do you mean by this and why do you think it is important? Would EPA need 

 additional statutory authority? 



4. You mentioned several cooperative programs or projects that EPA is working 

 with industry on such as Design for the Environment, SIDS, 33/50, testing consent 

 agreements, and voluntary risk reduction efforts. How do these fit with the core 

 TSCA program of reviewing and regulating specific chemicals? Are there conflicts 

 in these approaches?. How are you tr3dng to integrate them? Are there problems 

 with implementing these? 



5. What is the connection between TSCA and environmentally preferable prod- 

 ucts? 



New Chemicals 



6. 1 have been told that EPA's new chemical program is one of the more successfiil 

 aspects of the TSCA program. Yet, you've indicated that over 90 percent of the 

 roughly 2000 new chemicals EPA reviews annually are approved without any re- 

 strictions on their manufacture or use. What is your assessment of the new chemi- 

 cals program? 



7. Would the effectiveness of the new chemicals program be enhanced if there was 

 a certain minimum amount of testing and other information required before submit- 

 ting a premanufacture notice? Do you have any suggestions for the kind of data and 

 information that would be most useful? 



8. When TSCA was enacted, a good deal of thought was given to whether we 

 should have a pre-manufacture or pre-marketing system for review of new chemi- 

 cals. We embraced the pre-manufacture approach, but I know that other countries 

 have a pre-marketing system. Now that we have the benefit of nearly 18 years of 



