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Senator Reid. Dr. Geiser, EPA has suggested focusing on chemi- 

 cal use patterns and on specific geographical areas. 



What do you think of these approaches? 



Dr. Geiser. It reflects a little bit on the past comment. We see 

 that the way industry — particularly the user sectors of industry — 

 approach the question of toxic chemicals is within an array of deci- 

 sions about what chemicals to use to achieve certain functions in 

 industry. This is quite divergent from the way TSCA is written. 



We believe that there is great potential to work more collectively 

 and more cooperatively with firms when you are looking at an 

 array of substances or an array of technologies and trying to find 

 ways to guide industry toward safer substances. We heard Dr. 

 Goldman talk about the dry cleaning industry. EPA has also done 

 a printing project very similarly. And we have done others where 

 we have tried to look at a comparative set of different substances 

 together to try to give a list of different parameters about the ap- 

 proach. 



I believe that is an important way to move away from the chemi- 

 cal by chemical approach, which has so constrained the agency. 



Senator Reid. In your experience with the Massachusetts toxic 

 use reduction law, have there been difficulties defining what are 

 safer safer materials and cleaner cleaner technologies? 



Dr. Geiser. There are certainly difficulties on this. It is a long 

 struggle. We have a great deal of science and knowledge about how 

 to define risk and hazard. We have much less capacity to say some- 

 thing about what we want to get to, that is, a safer substance or 

 a cleaner process. It requires a good deal of interaction and dia- 

 logue and consideration, which involves things like life cycle assess- 

 ment, structure activity analysis, performance analysis. We have 

 been trsdng to develop protocols to teach people in business how to 

 assess their chemical uses in ways that allow them to see all the 

 factors that they might move that way. 



The second center I am director of— the Center for Environ- 

 mentally Appropriate Materials — has been spun out of a vision of 

 trying to find ways to use material scientists to begin to spec out 

 materials that will be safer. Again, the question of safe is a difficult 

 question to answer. 



Senator Reid. Ron Condray, on behalf of the chemical manufac- 

 turers, said that EPA needs to prioritize chemicals for testing so 

 that the attention is directed to the most serious concerns. Your 

 testimony I think also stresses this. 



Most people would agree with that. The problem comes in identi- 

 fying the priorities. 



Are there categories or criteria that EPA or Congress could es- 

 tablish that would guide priorities for testing? If so, what are they? 



Mr. Hagerman. I think that I would probably disagree that 

 chemically structured categories would be useful. I do think it is 

 possible to establish a screening mechanism — I talked about this 

 with several people over several years — a matrix based primarily 

 on exposure consideration that would consider things like produc- 

 tion volume on the one hand and use on the other hand, moving 

 from the uses with the greatest exposure to the least. 



But in any case, this would establish cells of chemicals where 

 there would be substantial widespread exposure and it seems to me 



