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achieve results in a much more timely and effective manner. Some important exam- 

 ples are summarized below: 



(1) The Use and Exposure Information Project is a voluntary initiative which will 

 result in the collection of valuable data on chemicals that are the focus of EPA's 

 Risk Management program. CMA and our sister trade association, the Synthetic Or- 

 ganic Chemical Manufacturers Association (SOCMA), volunteered over 15 months 

 ago to develop a process for collection of valuable and much-needed exposure and 

 use information from industry so EPA could make the necessary risk management 

 decisions about these chemicals under TSCA. Currently, this project is in a pilot 

 phase to finalize the process and form used for the collection of information. 



(2) As we have focused more on making information about our products available 

 to the public, we have responded to concerns about Confidential Business Informa- 

 tion (CBI) claims under TSCA. In an ongoing effort to reduce the number of inap- 

 propriate CBI claims, CMA developed a program of several CBI Workshops for 1993 

 and 1994 to educate industry about the CBI process. As a result of these workshops 

 and separate efforts by EPA, CMA is aware of a considerable reduction in improper 

 CBI claims. EPA representatives have publicly thanked CMA for its efforts and con- 

 firmed that recently there has been a significant, noticeable reduction in CBI abuses 

 and the filing of inappropriate claims. 



We are committed to continuing efforts to reduce inappropriate CBI claims and 

 thereby make more information about chemical products available to the public. As 

 part of the public comment period on EPA's CBI Reform Proposal, CMA has also 

 provided EPA with other ideas on improving access to information collected under 

 TSCA while still protecting valuable proprietary information from U.S. and global 

 competitors. 



(3) The Organization for Economic Cooperation and Development's (OECD) Exist- 

 ing Chemical Testing Program, which began in 1990, is a major, ongoing effort de- 

 signed to systematically review the potential human health and environmental ef- 

 fects of High Production Volume (HPV) chemicals on a voluntary basis. This inter- 

 national cooperative effort has required the commitment and ongoing participation 

 of many of CMA's member companies to progress toward the OECD's goal of making 

 screening level data (i.e., the Screening Information Data set-SIDs) available on 

 high-volume chemicals produced worldwide. 



CMA has provided leadership in this effort by finding sponsors for U.S. chemicals, 

 coordinating dossier reviews of non-U.S. chemicals, and collecting exposure informa- 

 tion to facilitate the program. Over 400 chemicals are currently moving through the 

 OECD-SIDs program. The high quality health and safety data gathered on these 

 chemicals is publicly available. The program also equitably shares the testing bur- 

 den on a global basis. 



From its inception, the OECD-SIDs program has been a voluntary program in the 

 United States. The SIDs activity has been over and above the normal mandated 

 TSCA Section 4 testing requirements. Even on those few occasions when the United 

 States has selected a TSCA Section 4 chemical for the SIDs program, U.S. industry 

 has had to do additional voluntary work to satisfy the SIDs requirements. 



CMA has also been working cooperatively with EPA to find sponsors for a vol- 

 untary initiative to develop screening level data on High Production/High Release 

 (HP/R) chemicals included in the Toxics Release Inventory. The overall intent is to 

 enter sponsored chemicals into the OECD SIDs progrtun. 



(4) In an effort to educate industry and the public about TSCA compliance and 

 cooperative initiatives, CMA and SOCMA have cosponsored four multi-day con- 

 ferences since 1989. Held at 18-month intervals, each conference brings together 400 

 to 500 representatives of industry, government, trade associations, law firms, and 

 the press. Companies have used these conferences to help train their employees who 

 will be responsible for TSCA regulatory and compliance matters. EPA representa- 

 tives, who have been invited to speak at the workshops, have used them as opportu- 

 nities to explain or review the Agency's interpretation of TSCA regulatory issues. 

 A number of new initiatives and joint cooperative programs were highlighted at the 

 most recent conference in April 1994. 



