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portant vehicle that should be added to the 6(a) provisions as a 

 remedy in regards to chemicals of concern. 



The last has already been mentioned a couple of times, which 

 has to do with the public access to the data. It is clear from the 

 TRI experience that just simply getting the information out pro- 

 vides a database that can be useful not only to the public, but also 

 to industry in thinking about shifts toward more environmentally 

 sound materials. We urge that the TSCA data under sections 8, 9, 

 and 10 be linked better to the TRI provisions. 



Thank you very much. 



Senator Reid. In your testimony, Mr. Guerrero, as I understand 

 it, you stress the need for Congress to establish clear goals in 

 TSCA for what EPA is to accomplish under the act. 



Could you elaborate on what goals are needed and why they are 

 needed? 



Mr. Guerrero. Yes. 



We believe there are two areas where it would be useful to estab- 

 lish clear goals for EPA under TSCA. The first is to put the review 

 of existing chemicals on a more equal footing with the current re- 

 view of new chemicals by giving EPA a very specific mandate to set 

 targets with certain time frames for accomplishing that. 



For example, telling EPA to identify a certain number of high- 

 risk chemicals, to publish those for comment 



Senator Reid. By a certain date? 



Mr. Guerrero. By a certain date — to get some comment and 

 agreement upon that list, and then to proceed to work coopera- 

 tively with industry to collect data over a set time frame on those 

 chemicals to resolve outstanding questions and then to go on to the 

 next list. That might be done on a 3-year cycle or a 5-year cycle 

 and so forth. 



But that is something very specific. Right now, the new chemical 

 reviews are required to be done in 90 days. They come in and by 

 and large they are done in 90 days. That is where the emphasis 

 goes because that is where there is a very specific expectation. 

 There is no such expectation for existing chemicals. 



The other goal is an overall goal that could be established in 

 TSCA to supplement the chemical by chemical approach we are 

 now using. That would require some mandated reduction in the use 

 of toxic chemicals overall over a certain period of time. It might be 

 a 25 percent reduction over 5 years or a 50 percent reduction in 

 10 years. 



Senator Reid. Rather than being chemical specific? 



Mr. Guerrero. Not so much rather, but in supplement to TSCA. 

 TSCA's authorities, as we have testified, do need to be strength- 

 ened to make that act more user friendly for EPA, but at the same 

 time it could be usefully supplemented with an overall goal for 

 toxic chemical reduction. 



Senator Reid. You have suggested changing the unreasonable 

 risk standard in section 6 and providing a two-step process. The 

 first step would be to establish that there is a significant risk and 

 then the second step would be that EPA would consider options to 

 manage that risk. Is that right? 



Mr. Guerrero. That is correct. 



