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countries? Does producing it, or recycling it, involve disproportionate amounts of en- 

 ergy? Can it be horizontally recycled back into the same use, or must it be cascaded 

 down to another use where reduced performance is acceptable? In short, what are 

 its overall environmental impacts over its lifecycle? 



Implications for TSCA and EPA 



A similar refocusing of TSCA in light of our more sophisticated understanding of 

 environmental impacts should be initiated. It remains important, of course, to con- 

 sider toxicity, but the first policy goal in TSCA should be reemphasized: "It is the 

 policy of the United States that>— (1) adequate data should be developed with respect 

 to the effect of chemical substances and mixtures on health and the environ- 

 ment. . . . " As with AT&T's concerns about materials, toxicity is only one dimen- 

 sion of this policy — ^but to date it is the one which has dominated TSCA activity. 

 That is unhealthy, both for policy and for the environment. In many cases, relatively 

 nontoxic materials can have far greater impacts than much more toxic materials 

 used in controlled conditions. CFCs are the exemplar of this principle: they are vir- 

 tually nontoxic, and yet their impact on biological systems, because of their impact 

 on the ozone layer, is potentially catastrophic. CO2 is also relatively nontoxic, yet 

 it may drive global climate change that could prove terminal to many species. The 

 point is not to deregulate toxics. Rather, it is to expand the consideration of what 

 our materials policies should be in this country to match our increased understand- 

 ing of environmental perturbations, and the impact of material production and flows 

 on them. 



Accordingly, the primary policy goal of TSCA should be expanded to call for the 

 development of data that begin to inform all of us — regulators, material producers 

 (including the mining, forestry and petrochemical sectors), material users, product 

 consumers — about sustainable material use in our economy. This will not be a triv- 

 ial task, and it will require not only the environmental science and toxicology com- 

 petencies of EPA, but in all probability the materials competency of; for example, 

 the Bureau of Mines, and the technology competencies of the Department of Energy 

 and the Department of Commerce. The new DoE Strategic Plan, Fueling a Competi- 

 tive Economy, released in April of this year, for example, recognizes that a critical 

 success indicator for their "Industrial Competitiveness" thrust is a "decrease in en- 

 ergy use, amount of raw materials, and generation of waste per unit of Gross Do- 

 mestic Product." (Page 13) I find it quite interesting — and encouraging — that this 

 success indicator appears not in the Environmental Quality thrust, but in the Indus- 

 trial Competitiveness thrust, as this indicates a recognition by DoE that environ- 

 ment, energy and industrial activity must be integrated and treated together. It is 

 also encouraging because the DoE National Laboratories are a unique resource for 

 providing the objective R&D, and technological competence, to support the evolution 

 of sustainable material flows within our economy. 



Certainly others must be involved. Industry will have to contribute data and ex- 

 pertise on their various technologies and resultant emissions. The public, and envi- 

 ronmental groups, will need to be included to ensure that no concerns are over- 

 looked or not addressed, and that risks are evaluated fi*om a comprehensive, not 

 just technical, perspective. International harmonization through UNEP, the OECD, 

 and ISO, based on good science and mutual respect, should be a goal. In this regard, 

 however, the tendency to discriminate against developing countries through trade 

 barriers or other mechanisms allegedly based on environmental criteria must be 

 avoided. 



What should EPA's role in this evolution be? Let me first say that I have the 

 greatest respect and admiration for EPA's Office of Pollution Prevention and Toxics, 

 and Mark Greenwood, its Director. What they have done with little funding and few 

 resources is inspiring, and should be emulated throughout the Agency. They cannot, 

 however, overcome certain fundamental constraints. For one, EPA as a whole is an 

 enforcement and compliance organization. This makes it quite difficult to launch 

 and maintain collaborative efforts with industry. Moreover, EPA's competency as a 

 Government entity is in environmental science and toxicology,. It is not in tech- 

 nology, or basic materials science, or design engineering. Accordingly, I believe that 

 EPA, and OPPT, must be important players, but cannot by themselves perform, the 



