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and costly. First and foremost among these changes is a reassess- 

 ment of the standards EPA must apply in regulating chemicals. To 

 regulate a chemical under TSCA, EPA must show that the chemi- 

 cal presents or will present an unreasonable risk. To determine 

 whether the risk is unreasonable, EPA assesses the chemical's 

 risks and performs extensive analysis to weigh the benefits of con- 

 trolling the chemical against the economic and social costs of any 

 contemplated regulation. 



But this test of reasonableness has been very difficult for EPA 

 because of the complexity and the amount of evidence required to 

 demonstrate that the benefits to human and health and the envi- 

 ronment outweigh the economic and social costs of controlling or 

 banning a chemical. EPA's inability to regulate asbestos, a known 

 environmental hazard, illustrates the difficulty of applying TSCA's 

 current standards. 



In contrast to TSCA, the Canadian Environmental Protection Act 

 separates the process of deciding whether to control a chemical 

 from the process of determining what appropriate control actions 

 should be taken. The act authorizes the government to control 

 chemicals that are toxic, which are defined as those entering the 

 environment in a quantity or concentration or under a condition 

 having a harmful effect on health and the environment. 



Determining whether the chemical is toxic and should be con- 

 trolled is based on an assessment of the chemical's risks. Costs and 

 benefits are taken into account in deciding what control actions to 

 take rather than in deciding whether a chemical's risks should be 

 addressed. 



EPA also needs better data for new and existing chemicals. Cur- 

 rently, new chemicals are manufactured with limited information 

 on their characteristics and effects. This occurs because TSCA does 

 not require the routine testing of new chemicals and industry per- 

 forms only limited testing. EPA relies on available data from 

 chemicals with similar molecular structures and, unfortunately, 

 this does not always sdlow it to predict important characteristics of 

 the chemicals being reviewed. 



To provide better data, TSCA could require manufacturers to 

 perform basic tests for new chemicals and additional tests when 

 production reaches certain levels. Although that would impose ad- 

 ditional burdens on both EPA and manufacturers, there is an op- 

 portunity to limit that burden by shifting the point of review from 

 premanufacturing to the time the chemicals are marketed. I would 

 be pleased to discuss this further in questions and answers. 



Even with better data on new chemicals, EPA will still lack ade- 

 quate information on most chemicals since 86 percent of the ap- 

 proximately 72,000 chemicals in the inventory existed in commerce 

 when the new chemical review program began and have not been 

 reviewed as new chemicals. In turn, only about 2 percent of these 

 existing chemicals have been reviewed. This lack of attention to ex- 

 isting chemicals is a result of both no explicit statutory require- 

 ment for EPA to review existing chemicals and the cumbersome 

 process the agency must use to collect data. To put the existing 

 chemical program on a more equal footing, Congress may wish to 

 consider setting specific deadlines or targets for those reviews. 



