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voluntary testing program. This program had several objectives 

 that I think are worth mentioning, including the validation of a set 

 of short-term tests that could be used for screening, application of 

 these tests to screen high production volume chemicals, and to es- 

 tablish a program which more equitably shares the economic bur- 

 den of testing among the members of the OACD. We think this pro- 

 gram was a real success. 



Considering the exposure element of risk evaluation, we believe 

 that EPA has ample authority under TSCA to gather exposure in- 

 formation needed for evaluating risk. For example, gross exposure 

 information can be collected through the TSCA inventory update 

 program where they find out whether the chemicals were produced 

 and how much. Detailed exposure assessment, at the other ex- 

 treme, can be very expensive and should be acquired only for sup- 

 porting severe controlling actions. 



This brings us to section 6. Dow believes that there are limited 

 circumstances where EPA should exercise primacy in controlling 

 exposures to chemicals through its section 6 authority. A congres- 

 sional definition of unreasonable risk would be helpful, but the risk 

 basis for regulatory action in the current language should be re- 

 tained. 



Mr. Chairman, I see that my time has expired, so I will just skip 

 to the end of my comments. 



I would like to thank you for the opportunity to present our 

 views on the implementation of TSCA. We look forward to working 

 further with the subcommittee as it considers it review of TSCA 

 and the need for reauthorization. 



Senator Reid. Thank you. 



Dr. Geiser? 



STATEMENT OF KENNETH GEISER, DIRECTOR, TOXICS USE 

 REDUCTION INSTITUTE, UNIVERSITY OF MASSACHUSETTS 



Dr. Geiser. Thank you, Mr. Chairman. 



My name is Ken Geiser. I am the director of the Toxics Use Re- 

 duction Institute and the Center for Environmentally Appropriate 

 Materials at the University of Massachusetts. 



The Toxics Use Reduction Institute works with over 600 firms in 

 Massachusetts, targeting a list that is ostensibly at 900 toxic 

 chemicals, although practically is about 146 high priority toxic 

 chemicals. We work with firms to assist them in the reduction of 

 use, elimination of use, and reduction of the waste streams from 

 those firms. 



We believe that we have learned a great deal from our pollution 

 prevention efforts in Massachusetts that might be relevant to the 

 reconsideration of TSCA. We would like very much to present that 

 to you. 



I have presented a testimony with more specific issues, so I will 

 just hit a few highlights. 



Let me start with the bigger picture here. The TSCA we have 

 seen in the past has been too tightly constrained in the way it has 

 been conceived. I believe that as we face the future, we need to be 

 about creating a national materials policy that moves us progres- 

 sively toward safer materials and more environmentally sound and 

 beneficial production operations. We see that TSCA opens up a 



