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STATEMENT OF LINDA ROSENSTOCK, DIRECTOR, NATIONAL 

 INSTITUTE OF OCCUPATIONAL SAFETY AND HEALTH, DE- 

 PARTMENT OF HEALTH AND HUMAN SERVICES 



Dr. RoSENSTOCK. Good morning, Mr. Chairman. 



I welcome this opportunity to comment on the role that NIOSH 

 plays in implementing the Toxic Substances Control Act and offer 

 some suggestions on now data obtained under the act could more 

 effectively be used to increase worker health and safety. 



NIOSH, too, supports the principle of pollution prevention. Our 

 mandate under the Occupational Safety and Health Act is to con- 

 duct research on innovative methods, techniques, and approaches 

 for preventing occupational safety and health problems, including 

 those created by new technologies. 



Based on this research, we develop recommended standards and 

 the criteria needed by OSHA and MSHA for standards promulga- 

 tion. We are also required to conduct informational programs on 

 the importance of and proper use of adequate safety and health 

 equipment. These are all preventive mandates. 



We firmly believe that preventing harmful exposures is the key 

 to avoiding human suffering and death through exposures to work- 

 place hazards, as well as take-home hazards that can expose family 

 and community members. NIOSH strongly supports the concept 

 that it is the responsibility of chemical manufacturers, processors, 

 and formulators to test, review, and appropriately inform users and 

 consumers about the hazards and proper use of their chemicals. 



Since the Occupational Safety and Health Act does not require 

 industry to test the chemicals it manufacturers and uses, it is 

 through data generated under TSCA and by membership on the 

 interagency testing committee, which makes recommendations to 

 the Administrator of EPA on priority chemicals for rulemaking, 

 that NIOSH can obtain some of the toxicity information needed for 

 standards development and targeted research and preventive re- 

 search programs. 



I would like to just mention a couple of activities we have played 

 with staff of EPA in implementing TSCA. We have worked closely 

 with EPA and OSHA to coordinate key policy issues related to toxic 

 substances. Since becoming director of NIOSH in April, I have met 

 regularly with Dr. Goldman and Joe Dear on these and other is- 

 sues. 



NIOSH activity related to TSCA include but are not limited to 

 some of the following. We have active membership and have had 

 chairmanship on the interagency testing committee; participation 

 in EPA stewardship meetings with industry; peer review of docu- 

 ments and participation in risk management meetings; conducting 

 industrial hygiene surveys through an interagency agreement to 

 provide EPA with exposure assessments of various industries. 



Section 4(a) of TSCA permits EPA to require the testing of any 

 chemical which may present an unreasonable risk of injury to 

 health or the environment. In promulgating such a testing require- 

 ment rule, EPA may prescribe epidemiologic studies, those studies 

 of actual working populations, after consultation with NIOSH. 

 NIOSH believes that tnis route of approach should be pursued ag- 

 gressively and that results from actual studies of employees would 

 be beneficial and is eager to work closely with EPA on this issue. 



