85 



tons, and insulation. Every migor industry is impacted by regulation of chemicals. 

 From construction to computers, from medicine to the military-TSCA impacts them 

 all. 



Similarly, environmental regulation of these other industries has had a tremen- 

 dous impact on the chemical industry, and the products it creates. For example, as 

 the Clean Air Act Amendments of 1990 have begun to take effect, there is tremen- 

 dous energy in the chemical industry to develop substitutes for those products that 

 contribute to ozone depletion, ozone formation, or result in emissions of hazardous 

 air pollutants. Costly waste management regulations and landfill restrictions that 

 fall on our customers as well as our member companies also are forcing product re- 

 design and redevelopment to meet customer needs with reduced environmental and 

 regulatory impacts. 



Our Commitment 



Our industry is committed to protecting health, safety and the environment in a 

 manner that yields the greatest protection possible for the amount of resources used 

 by setting priorities for action based on the risk posed. The direction in which our 

 industry is steadfastly moving reflects its ongoing commitment to the mandates of 

 TSCA, responsible management of risks, and stewardship of our industry's products 

 throughout the life cycle of a product. 



CMA member companies are committed to continuous improvement in chemical 

 management We initiated this commitment by formally adopting our Responsible 

 Cared program in 1988. Under this initiative, CMA member companies have com- 

 mitted themselves to continuous improvement and are backing up that promise with 

 tangible actions. Responsible Cared is being implemented through a series of Codes 

 of Management Practices. CMA started its Responsible Cared Program with the 

 Community Awareness and Emergency Response (CAER) Code, the goals of which 

 were to improve our industry's relationship with the public and community. CAER 

 addressed concerns about the need for the industry to be more open with commu- 

 nities about its operations and emergency planning procedures. 



Five other Codes of Management FVactices have been approved since. The most 

 recent one, the F*roduct Stewardship Code, most closely parallels the goals and risk- 

 based framework of TSCA because of its life cycle focus on chemical product man- 

 agement This Code, approved in the Spring of 1992, is the broadest and most chal- 

 lenging of the Codes. "The Product Stewardship Code encompasses the entire product 

 lifecycle and emphasizes product management through a number of methods, in- 

 cluding improved communication and partnership with third parties, such as cus- 

 tomers, distributors, suppliers, and contract manufacturers. As a voluntary industry 

 initiative. Product Stewardship does not focus exclusively on significant or unrea- 

 sonable risks, but rather attempts to make improvements at all levels of potential 

 risks. 



In the Product Stewardship Code, our industry has articulated its vision for the 

 responsible management of chemicals beyond that required by Federal laws and reg- 

 ulations. We are now in the process of generating a wide range of resource materials 

 to assist our industry and others with implementing the Code. These resources are 

 discussed in more detail below. 



Our Accomplishments 



As a part of this changing environmental ethic, we have gone beyond simply meet- 

 ing TSCA requirements and are working cooperatively with EPA and the public on 

 voluntary initiatives to promote an informed public dialogue on the risks and bene- 

 fits of industrial operations and products. CMA's track record reflects that we have 

 not waited for change but instead have been promoters of change through our own 

 voluntary initiatives. 



We believe voluntary cooperative efforts offer unique advantages that make them 

 superior, in many ways, to regulatory actions. Voluntary actions are more timely, 

 flexible, performance (or goal) oriented, cost-efiective, and can make use of state of 

 the art approaches and new data. Such efforts encourage innovative approaches and 

 creative solutions not otherwise available under regulatory programs and can often 



