107 



NIOSH does use data generated from the TSCA chemical testing 

 program in many ways. For example, we use the data to assist in 

 selecting chemicals for developing criteria documents, including 

 some which have been jointly written with the Nordic group of ex- 

 perts and Swedish National Institute of Occupational Health. 

 NIOSH is pleased that the interagency testing committee is rec- 

 ommending that testing be conducted to obtain data for prevention 

 activities, including regulations. 



These kinds of data will play a significant role in the current ef- 

 forts by NIOSH and OSHA to jointly develop priorities for regu- 

 latory and other prevention activities. 



NIOSH also uses TSCA data in compiling the congressionally 

 mandated NIOSH database, known as RTECS, the Registry of 

 Toxic Effects of Chemical Substances. This database is used inter- 

 nationally in a variety of formats to identify toxic effects of over 

 120,000 chemicals. TSCA data are used by NIOSH to develop docu- 

 ments for informing employers and employees about workplace 

 hazards. 



These data are also used in developing recommended standards 

 and associated criteria for use by OSHA and MSHA. They may also 

 be used by a research scientist formulating hypotheses for further 

 research, 



NIOSH is pleased that EPA has proposed the reformulation of 

 the toxics released inventory to assist us in collecting information 

 to update workplace surveys conducting from 1971 through 1974 

 and again from 1981 through 1983. These past surveys have been 

 an invaluable source of information used by numerous Federal pro- 

 grams, including the interagency testing committee, the national 

 toxicology program, and NIOSH and OSHA for developing regu- 

 latory research and testing agendas. 



EPA has recently proposed a pyramid structure with TSCA data 

 forming the base, NIOSH in the middle interpreting the data and 

 supplementing it with industrial hygiene, medical, and risk man- 

 agement information, and transmitting recommendations to the 

 Department of Labor for regulatory action. This scheme is a prom- 

 ising one, and if perfected and implemented, it would improve the 

 ability of these agencies to protect the health and safety of workers 

 and the general public from exposure to toxic chemicals. We will 

 continue to work with EPA and OSHA on implementation of this 

 proposal. 



One frustration with all chemical testing performed through Gov- 

 ernment agencies is the long lead time needed to obtain test data. 

 The common minimum of 2 to 3 years before testing begins on a 

 targeted chemical does not even include the actual test time, report 

 writing, and review processes before the information is available. 

 Obviously, this hurdle needs to be addressed. 



Another serious problem is the limitation on the use of confiden- 

 tial business information either for planning, research, or in formu- 

 lating recommendations to the Department of Labor. We need to 

 clearly define better guidelines on what constitutes an appropriate 

 use of confidential business information so that this information is 

 not used to prevent identification of hazards about which we can 

 intervene and reduce risk. 



