73 



Further indexes could indicate whether submissions have been peer reviewed and 

 whether evaluations or related information are available. Supplemental abstracts or 

 summaries would be helpful, if available. 



• Develop appropriate data products and services (without high costs, dif- 

 ficult learning curves, or user-unfriendly software) ^ For example, EPA could 

 provide facilitated computer searches for chemical specific information, facility 

 and parent company identification, or total claims. 



• Reduce the need to challenge CBI claims. A program structure that results 

 in the perpetual dedication of resources to challenge CBI claims is designed to 

 fail. To reduce the burden of challenging CBI claims, the agency should require: 



— up-front substantiation; 



— penalties for unsuitable or frivolous claims; 



— the signature of a high level official; 



— fees for CBI claims (only); and 



— routine rejustification of claims. 



Penalties were not included among EPA's proposals, but should be. Education 

 courses (noted in the proposal) are not a substitute for class determinations that 

 indicate clearly which information may or may not be claimed as CBI. 



• Cultivate natural data constituencies; don't exclude them. Data outlets in- 

 clude: State officials; product designers and materials researchers; consumer, 

 labor, and environmental groups; and other decision makers. "* ^ 



These principles must apply to all submissions, whether material contained with- 

 in the submission is public or CBI. These are cost-effective changes that, if imple- 

 mented, will provide people with a reasonable expectation of finding useful informa- 

 tion in a comprehensive context. In that case, tiie public too will find TSCA data 

 usefvil. 



Sincerely, 



Paul Orum, 

 Coordinator. 



3 Such problems were identified in "The TSCATS Database: A Survey of Current and Potential 

 Users," (Hampshire Research Associates, Inc., 1992), pp. 20-24. 



*The U.S. General Accounting Office has recommended that agencies reorganize their data 

 bases to make reproductive and developmental data available to decision makers. See "Repro- 

 ductive and Developmental Toxicants — Regulatory Actions Provide Uncertain Protection," (Octo- 

 ber 1991, GAO/PEMD-92-3). 



6 TSCA data can help State officials to: enhance data bases; improve risk assessments; design 

 £ind enforce regulations; implement right-to-know Laws; prepare for or respond to emergency re- 

 leases; and, in general, to understand the industries they regulate (comments of the State of 

 California, March 29, 1993). 



