88 



lieves its responsibilities are continuing improvement in risk management and prod- 

 uct stewardship. Such responsibilities are carried out under TSCA, through vol- 

 untary cooperative efforts with government, and separately through private sector 

 initiatives such as CMA's Product Stewardship Code. 



Question: What cooperative programs has industry entered into with EPA? 



Our voluntary cooperative efforts with EPA (see pages 9 through 15) have been 

 discussed in our written testimony above. We can provide you with additional de- 

 tails on any of these programs at your request. 



Question: What are CMA's ideas on increasing the existing body of knowledge 

 about health and environmental effects of toxic chemicals? 



CMA believes that information to manage risks of new or existing chemicals 

 should be available. While CMA supports EPA's authority and need to gather this 

 information, the Agency should look first to existing data and information. A great 

 deal of information on chemical substances is available and has been submitted to 

 EPA under TSCA and other regulatory programs but is not always readily acces- 

 sible. 



EPA should also continue to rely on Structure Activity Relationships (SAR) to 

 make predictions about the health and environmental effects and potential risk of 

 chemicals. SAR is a reliable predictor that relies on chemical structural analogues. 

 It is used by both EPA and industry to make assessments of chemicals. 



The purpose of a regulatory testing program should be to develop information nec- 

 essary to manage risks: Section 4 of TSCA should not be a basic research program. 

 Regulatory testing programs should prioritize chemicals for testing in a way that 

 directs testing resources to serious concerns first and requires the collection and 

 careful evaluation of existing exposure and toxicological information prior to a test- 

 ing decision for the most effective risk management benefits. 



The evaluation of the amount and kind of data needed to manage the risks of a 

 chemical should proceed in a step-wise fashion from screening level information to 

 progressively more complex testing. CMA supports the internationally recognized 

 and accepted tests used in the OECD Screening Information Data Sets (SIDs). 



The OECD SIDs program has also effectively encouraged the sharing, internation- 

 ally, of data and testing on high production volume chemicals. CMA has made con- 

 siderable efforts to promote the international sharing of the testing burden and ad-' 

 vocate mutual acceptance of data. 



Question: Does the current statute set an appropriate balance between manufac- 

 turers' interest in protecting confidential business information and the public's in- 

 terest in having information publicly available? 



CMA supports EPA's authority under TSCA to collect and the public's right to 

 know information on the significant health and environmental effects associated 

 with chemicals. We believe the statute, as written, strikes the proper balance on 

 confidential business information (CBI). However, EPA and industry can do more 

 and are doing more to make information available to the public while continuing 

 to protect proprietary information. 



CMA has found voluntary efforts to be particularly effective in making more of 

 the information collected under TSCA available to the public by reducing the num- 

 ber of inappropriately filed CBI claims. EPA has publicly acknowledged a significant 

 drop in CBI claims recently and credits CMA's education workshops as being par- 

 ticularly effective. 



We continue in a dialogue with EPA on this issue and are discovering creative 

 solutions to releasing significant health and environmental effects information with- 

 out threatening valuable proprietary interests. 



CONCLUSION 



The world and how chemical risks are managed have changed a great deal in the 

 last 20 years. TSCA was and still is a sound approach to the management of chemi- 

 cals, but it is no longer the sole vehicle for their regulation. Other statutes have 

 stepped in to regulate chemical substances and now complement TSCA's authority. 

 Besides these regulatory programs, cooperative and voluntary initiatives are produc- 

 ing significant improvements and enhancements in risk management. We believe 



