98 



truly bad and so harmful in many uses that it needs to be banned 

 or severally restricted, like DDT or PCBs. 



More often, however, the hazards stem from certain uses of cer- 

 tain chemicals. The challenge is managing these uses to minimize 

 risks. 



In some respects, TSCA was not really set up for this challenge. 

 As one of our previous witnesses indicated, TSCA anticipates a 

 Government solution for individual chemicals. But our chemical 

 world is much more complex. A long-term toxics program requires 

 a change in mindset. A system that awaits word from the Govern- 

 ment that X chemical must be tested and Y chemical must be re- 

 stricted is not much of a system at all. It sends the message that 

 a chemical manufacturer only has to react to explicit Grovemment 

 requirements, but chemical manufacturers and processors them- 

 selves must be responsible for understanding the environmental 

 and health consequences of the chemicals anybody can use. 



I know that many an industry — and especially the Chemical 

 Manufacturers Association, with its responsible care program — rec- 

 ognize their responsibility and have made commendable strides in 

 this direction. But TSCA needs to do more. 



I think it is important to bring these concepts to TSCA. As sev- 

 eral witnesses pointed out in May, TSCA is one of the few multi- 

 media environmental statutes. It gives EPA authority to regulate 

 at any point between manufacture and disposal. In addition, as I 

 have noted before, its new chemical provisions were among the ear- 

 liest experiments of pollution prevention. That concept of reducing 

 or eliminating hazards before we release a substance into the envi- 

 ronment should be extended to TSCA's existing chemical program. 

 In fact, EPA is doing this now in several of its projects. 



At the May hearing, Dr. Goldman mentioned EPA's designed for 

 the environment program, which assists companies in developing 

 substitute materials and processes that are better for the environ- 

 ment than a company's current practice. Today, Dr. Goldman will 

 tell us about one particular project involving dry cleaners that il- 

 lustrates this approach. TSCA should encourage these kinds of co- 

 operative efforts to serve the goal of preventing pollution. 



We have heard several useful and original suggestions for 

 changes to TSCA and will hear more today. 



I would now like to offer some of my own thoughts. 



To prevent managed chemical risks over the long term, I see es- 

 sentially a three track system. First, for new chemicals, we must 

 weed out from the start those chemicals that are likely to present 

 unacceptable risks. To do this effectively, we must have better in- 

 formation than we do now. 



EPA should not be in the position of speculation regarding the 

 characteristics of these chemicals. The United States has one of the 

 few programs that does not require some up-front testing before a 

 new chemical can enter the market. I believe that the OECD's 

 SIDS program provides a useful model for the kinds of tests that 

 could be required. 



We also need to better monitor these new chemicals once we let 

 them into commerce. We should know when their production level 

 and use has changed significantly from original estimates. With 



