84 



Occupational Safety and Health Act Hazardous Materials Transportation Act 



Marine Protection and Sanctuaries Act 



Federal Food, Drug, and Cosmetic Act 



Poison Prevention Packaging Act 



Flammable Fabrics Act Surface Mining Control and Reclamation Act and, 



Federal Mine Safety and Health Act 



In addition, chemical regulatory regimes have been established internationally, 

 and in some circumstances even at the State and local level. 



The world has changed in the last two decades, from a more closed corporate soci- 

 ety with a national outlook to a global economy in which companies are both multi- 

 national and multi-cultural in their perspective. U.S. company holdings abroad have 

 doubled between 1982 and 1991 (from $3.5 trillion in 1982 to $7 trillion in 1991). « 

 Two statistics illustrate the global nature of the chemical industry in the 1990s: 

 (1)15 percent of all U.S. chemical shipments were exported in 1993 (compared to 

 only 10 percent in 1983). (2) A recent survey showed that more than 27 percent of 

 CMA's members are now U.S. affiliates of foreign-based companies. "^ 



The public's expectations of corporate behavior have changed radically in the last 

 20 years. Corporations are now expected to be, and in fact are, more open with the 

 public and responsive to inquiries about their businesses, operations, and plans for 

 future development. Under many federal, state, and local laws, communities are 

 given a voice in whether or not facilities are sited and, if so, under what terms and 

 conditions. As the public has grown more environmentally conscious, U.S. corpora- 

 tions are relying more on partnerships and cooperative efforts with government and 

 less on adversarial interactions and court proceedings. Consumers, armed with in- 

 formation about products and the manufacturing process, are influencing corporate 

 behavior by their purchasing practices. 



Keeping pace with public expectations, our industry has changed considerably in 

 the last 20 years. At one time, we viewed our primary roles as buyers and sellers 

 of individual chemicals, identifying our customer's need, and developing a chemical 

 product to meet that need. 



Today we see otu-selves as product stewards. In addition to developing chemicals 

 that perform as needed, we also focus on the life-cycle impact of our products. 

 Through testing and analysis, we evaluate the health and environmental effects of 

 our products from research and development through commercialization and ulti- 

 mately disposal. 



The enactment of TSCA in 1976 is an important contributor to this shift in philos- 

 ophy to life-cycle awareness, as are the many subsequent environmental laws. Along 

 with voluntary industry initiatives and public expectations, TSCA has fostered prod- 

 uct stewardship within companies. However, many of the changes in corporate be- 

 havior that have occurred are often not observed by the public, the regulators, or 

 Congress. These changes cover company internal procedures, improved workplace 

 practices, better vendor and customer information, and communications concerning 

 safe practices. TSCA also has caused companies to conduct more careful analysis 

 and screening of new chemicals before manufacture at the research and develop- 

 ment stage and to consider rejecting chemicals for further production because of 

 screening results or evaluation during the EPA Premanufacture Notice review. 



CMA recognizes the world has changed. We understand that chemical regulation 

 under TSCA does not simply impact the chemical industry but influences the entire 

 manufacturing sector. Regulation of the chemical industry, in sum, impacts many 

 other industries because our products are critical to every aspect of modern life. 

 Chemicals are essential in modem manufacturing and are building blocks of vir- 

 tually every consumer product. 



For example, methane is a major organic building block chemical used to manu- 

 facture floor pohsh, dinnerware, auto parts, pens and pencils, and appliance parts. 

 Butadiene is used to manufacture apparel, upholstery, carpet, seat belts, and fishing 

 line. Xylene is used to make home furnishings, beverage bottles, bowling balls, but- 



8 U.S. and World Chemical Trade (CMA, January, 1994) at pp. 4-6, 5-4, and 5-13. 

 'CMA Economic Survey: Economic Outlook for 1994 and Beyond (February, 1994) at A-1 and 

 2. 



