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chance to do that, but in order to do that, it needs to be considered 

 in a broader perspective. 



Specifically, let me comment on several of the things that I think 

 need to be done. 



We need a broader and more comprehensive image of the TSCA 

 capacity. In this line, we believe it is necessary to focus on the use 

 and production of chemicals as much as upon the release. We 

 would look to section 8 as a new vehicle for expanding data collec- 

 tion efforts around the use and production of chemicals. The EPA's 

 current inventory update rule is a useful vehicle, but it is not broad 

 enough to be able to give us a full picture of materials flows, mate- 

 rials in use in commerce in the United States. 



Our effort in Massachusetts of looking at use data and not sim- 

 ply release data has dramatically changed the way we have tar- 

 geted our program in Massachusetts and given us a different way 

 of uniting our occupational health and safety work with our public 

 health work. We have not relied substantially on TSCA data be- 

 cause of the problems that we have had not only with its compat- 

 ibility to the needs of Massachusetts, but also with the CBI limita- 

 tions, which we believe cloud the data in such a way that it makes 

 it very difficult to act as a true mirror on the kinds of things we 

 want to set policies about. 



The second thing I would urge that we think about with TSCA 

 is to be much more proactive and to use TSCA to promote a dia- 

 logue about safer materials and about the development of new ma- 

 terials. TSCA currently acts as a net to keep us away from some 

 of the most dangerous materials. We believe that the future is 

 going to be more about how government works with industry to- 

 ward the development of materials that will be sounder and better. 



TSCA needs a new section dealing with the promotion of re- 

 search and development on new materials that will replace some 

 of the current materials that are such a concern to us. 



We believe further that it is important that TSCA be seen as a 

 load sharing law in which more responsibilities for chemicals be 

 shifted to the firms. You have already heard several comments 

 about testing, so I won't go into those. One that I believe we should 

 look at substantially is the question of how to work with industry 

 around the phasing out of certain high-volume, high toxicity, high 

 exposure chemicals. 



In this area, we in Massachusetts are looking at a four-step proc- 

 ess for moving from a voluntary to an assisted to a potentially 

 mandatory system of phasing down on certain of our most worri- 

 some chemicals. We believe that a staged process that works collec- 

 tively with industry, with producers, and particularly with the 

 users — who are those who find the most difficult problems with the 

 chemicals — would be a great advantage. This should be tied into 

 section 6 as a rewrite of the provisions, which currently lean more 

 toward bans and other such capacities, which have been of limited 

 use in the law. 



Thirdly, I believe that it is really quite important that we pay 

 attention to the pollution prevention work that has been going on 

 in the States, lead industries, and as a commitment of the Federal 

 EPA. We in Massachusetts have just completed the requirement 

 that 600 firms produce plans. We believe that planning is an im- 



