91 



Statement of Braden R. Allenby, on Behalf of AT&T 



My name is Braden Allenby, and I am the Research Vice President, Technology 

 and Environment, for AT&T. In that capacity, I have the responsibility for integrat- 

 ing technology and environment into AT&T's products, processes, services and oper- 

 ations around the world. I am also the Technical Vice Chairman of the Institute of 

 Electrical and Electronic Engineers, Inc. (IEEE) Committee on Environment, Health 

 and Safety, with the responsibility for creating and coordinating the position of the 

 IEEE on issues involving technology and the environment. Mr. Chairman, members 

 of the subcommittee, I would like to thank you for the opportunity to testify here 

 this morning on the Toxic Substances Control Act (TSCA), and how it may be 

 strengthened and improved. I particularly want to commend you for seeking testi- 

 mony from a representative of the chemical user community, as we frequently feel 

 somewhat overlooked on TSCA issues, even when our interests are being consider- 

 ably affected. 



My testimony today will fall into two sections. In the first, I will explain how the 

 role of chemicals — more broadly, materials — is changing in modem manufacturing. 

 I will then discuss the implications of this trend for TSCA, and how it should be 

 changed to reflect our increasing understanding of the fundamental challenges in- 

 herent in integrating economic and environmental goals. TSCA should be refocused 

 to encourage patterns of material use which are sustainable over the long term in 

 an environmentally constrained world, while supporting continued economic devel- 

 opment. AT&T's experiences in developing and implementing Design for Environ- 

 ment (DFE) methodologies, based on the evolving theory of Industrial Ecology, indi- 

 cate that this is a challenging and fundamental requirement for supporting indus- 

 trial activity which "treads lightly on the world." 



in the second portion of my testimony, I will discuss some of the concerns the 

 chemical user community has traditionally had with elements of TSCA and its im- 

 plementation. I will also suggest some general improvements which will reduce un- 

 necessary regulatory burdens while at the same time improving compliance and pro- 

 tection of the environment, health and safety. 



Moving TSCA Towards Sustainable Materials Use 



Modem manufacturing firms do not think of materials in the same way as they 

 did 10 years ago — or 18 years ago, when TSCA was originally passed. "Two basic 

 trends combine to dramatically change the way such fiirms must manage materials, 

 and, concomitantly, the importance of proper choice and use of materials for remain- 

 ing competitive. 



Materials Choice and Management in a Competitive Economy 



The first trend reflects differences in products, markets, and the competitive envi- 

 ronment. In most sectors, from, electronics to machine tools to aviation, competition 

 has increased dramatically in the past decade, partially reflecting the globalization 

 of markets for manufactured articles. Products must be designed to be lighter, and 

 to provide greater functionality with less energy consumption and at less cost. Many 

 electronics products, such as computers, have gone from large rooms filled with 

 humming boxes, to people's laps. 'Time-to-market" has become a critical deter- 

 minant of market success, more important in some cases than cost. Manufacturing 

 operations have shifted frova relatively inefficient modes where inventory was stored 

 at each stage of the process, to "just-in-time" structures where materials, compo- 

 nents and assemblies are delivered only as they are required in the next step of the 

 manufacturing process. 



This evolution of the market has two implications. First, it makes management 

 and choice of materials much more critical to competitive success. The lightest poly- 

 mer which meets performance specifications; the best solder/flux combination; the 

 best surfactant in an aqueous cleaning system — these can make the difference be- 

 tween an appealing product launched on time and meeting customer specifications, 

 and a commercial failure. Moreover, the manufacturing system becomes much more 

 sensitive to disruptions in material supply because of its rapidly changing, just-in- 

 time nature. Material inventories which used to buffer the system at every stage 

 are no longer maintained. Accordingly, the costs imposed on users by any disruption 



