57 



experience, what are your thoughts on the advantages and disadvantages of these 

 two approaches? 



9. We have an ever-increasing universe of chemicals with the hundreds of new 

 ones annually. Are any of these new chemicals substitutes for higher risk existing 

 ones? 



10. What would you think of an approval process for new chemicals like FDA has 

 for new drugs? 



Testing of Existing Chemicals 



11. Do you think there is a need for increased testing to learn more about the 

 health and environmental effects of existing chemicals? If so, do you have any sug- 

 gestions of how we could accomplish this? Should there be some essentially "auto- 

 matic" testing for certain chemicals? What might be the appropriate triggers)? 



12. It seems that the SIDS program has made good progress in obtaining at least 

 initial screening data on chemicals: approximately 300 are in some stage of testing. 

 In contrast, it has been a slow process getting test rules under section 4. What do 

 you think accounts for the difference in progress? Would EPA need additional au- 

 thority to obtain testing by administrative order? 



13. I am aware that EPA is working with industry on a voluntary project to in- 

 crease EPA's use and exposure information. I have been told that this type of infor- 

 mation is often lacking when EPA reviews a chemical. Can you tell me how well 

 this project is working? Is EPA considering other options to get this information? 

 Could and should such information be required through the' statute? 



Review of Existing Chemicals 



14. With over 70,000 existing chemicals in commerce, I am interested in under- 

 standing how EPA prioritizes its review of these chemicals. I know that you focus 

 on non-pol5miers that are produced in quantities greater than 10,000 pounds annu- 

 ally. However, as I understand it, this leaves 14,000 chemicals, still a daunting 

 number. What are the key factors you consider to prioritize your review and what 

 is the process for review? 



15. Along the same lines, are there particular categories of chemicals that are 

 highlighted in your review? If not, what do you think of this sort of approach? What 

 categories should have priority consideration? 



Managing Existing Chemicals 



16. Why do you think there have there been so few regulations under section 6? 

 Are there really so few unreasonable risks from chemicals? Is it too difficult to jus- 

 tify that finding? Or is the diflBculty in controlling risks through the particular 

 measures stated in section 6? 



17. I am interested to know what you see as the role of section 6. Especially in 

 light of the Fifth Circuit's rejection of EPA's asbestos rule, the section certainly 

 seems severely limited. Has EPA issued any section 6 rules since that decision? 

 What do you see in the future for that provision? 



18. In your testimony, you stated that there should be a preference for pollution 

 prevention as a means to reduce or eliminate significant risk. What exactly do you 

 mean by this? You also stated that the Fifth Circuit's asbestos decision read into 

 TSCA the opposite preference for "end of pipe" regulations. What do you mean by 

 this? How could section 6 reflect what you see as the correct preference? 



19. You talked about considering chemical uses, looking at groups of chemicals by 

 their uses when considering risk reduction. Could you explain in more detail what 

 you mean by this? Do you think there are changes in the statute that would facili- 

 tate this "use-cluster" approach? 



Information 



20. Why do you think that making more information public is important? What 

 are the main obstacles to increasing dissemination of information to the general 

 public, to other federal agencies, and to the states? With regard to the limited re- 

 sources available to the Agency, why is it important to increase the number of par- 

 ticipants involved in chemical management? 



