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STATEMENT OF HUGH M. SMITH, VICE PRESIDENT FOR RE- 

 SEARCH AND ENVIRONMENTAL SCIENCE, COLORS GROUP, 

 SUN CHEMICAL CO., REPRESENTING THE SYNTHETIC OR- 

 GANIC CHEMICAL MANUFACTURERS ASSOCIATION, INC.; AC- 

 COMPANIED BY CHERYL MARTIN, GOVERNMENT RELATIONS 

 MANAGER 



Dr. Smith. My associate is Ms. Cheryl Martin, the government 

 relations manager. 



Good morning, Mr. Chairman. I also have a written statement 

 for the record. 



Senator Reid. Without objection, your prepared statement will 

 appear in the record. 



Dr. Smith. I am Hugh M. Smith, vice president of research and 

 environmental science for the Colors Group of Sun Chemical Cor- 

 poration and vice chairman of the TSCA Committee of the Syn- 

 thetic Organic Chemical Manufacturers Association, known as 

 SOCMA. 



For your information, SOCMA is a trade association serving 

 more than 225 companies that have a common interest in the man- 

 ufacture, distribution, and marketing of organic chemical products. 

 The majority of SOCMA's members are small specialty chemical 

 manufacturers with annual sales under $40 million, most of which 

 are subject to TSCA reporting requirements. 



Today, I will summarize SOCMA's observations on EPA's exist- 

 ing chemicals program and also share with you SOCMA's two rec- 

 ommendations on how this program can be improved. 



First of all, let me say that SOCMA is committed to not only 

 helping its members comply with TSCA, but helping them work to- 

 ward continuous improvement goals. SOCMA is a partner associa- 

 tion in the Chemical Manufacturers Association's responsible care 

 initiative, a program developed to improve the chemical industry's 

 environmental safety and health performance. 



What does SOCMA think about EPA's existing chemicals pro- 

 gram? We believe that since 1990 EPA has truly been revitalized 

 in using its TSCA authority to implement initiatives under the ex- 

 isting chemicals program that are risk-based, action-oriented, and 

 focused on pollution prevention. SOCMA is generally supportive of 

 EPA's new initiatives and is participating in some of the ongoing 

 dialogue between the agency and industry in this regard. 



For example, SOCMA and CMA are working together with a vol- 

 untary initiative called the use and exposure information project — 

 already referred to in previous testimony — ^that is expected to re- 

 sult in a method whereby industry can submit use and exposure 

 data to EPA on a routine basis. EPA anticipates using this infor- 

 mation for its risk management or RM programs, a tier decision- 

 making and review program of which SOCMA is very supportive. 



There has been a great deal of talk already today regarding con- 

 fidential business information, or CBI. Let me say that SOCMA is 

 committed to working with EPA to eliminate any unwarranted CBI 

 claims, but urges Congress to maintain the current level of CBI 

 protection should it amend the act. The protection of confidential 

 business information is vital to many SOCMA member companies 

 because the specialty chemical industry is highly competitive. 



