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low-on testing and risk management efforts. The Master Testing List includes not 

 only individual chemicals but also generic chemical categories of emerging concern 

 about their environmental significance. Examples include persistent 

 bioaccumulaters and chemicals that may behave as "environmental hormones." 



EPA is using the TSCA testing authorities to address the testing needs set forth 

 in the Master Testing List. However, the statute puts a significant burden on EPA, 

 both in the findings it must make and the processes it must use, to obtain needed 

 test data. Once issued, these rules have faced substantial litigation. In short, there 

 are high transaction costs in using TSCA testing authorities. Recently EPA has em- 

 phasized the use of negotiated enforceable consent agreements and voluntary agree- 

 ments to improve the program's productivity. These agreements are not mechanisms 

 explicitly recognized in the statute. Although they have helped produce results, 

 there still is a wide gap between the testing needs of the Federal government and 

 TSCA's ability to meet that need. 



Risk Management 



I'd like to turn now to our existing chemicals risk management program. In many 

 ways, the changes in our risk management activities parallel — and complement — 

 the strategic changes we've made to our testing program. Current targeted risk 

 management actions are usually risk-based, using exposure and hazard criteria. Ac- 

 tions can be organized by specific chemicals, by clusters of chemicals defined by con- 

 cern or use, or by facilities. Appropriate pollution prevention or other risk manage- 

 ment approaches, either voluntary or regulatory, are developed to address these 

 chemicals of concern. 



While our risk management projects have traditionally involved particular chemi- 

 cals, increasingly we are managing clusters of chemicals used to perform a particu- 

 lar task. This "use cluster" approach seeks to compare risks of the various chemicals 

 that are alternatives within a technological or economic niche. The task is to iden- 

 tify those chemicals and/or technologies that represent a safer way of performing the 

 essential function in a cost effective manner. There are several advantages of the 

 use cluster approach. Use clusters force consideration of the comparative risks in- 

 volved in substituting chemicals and both the opportunities and limits of techno- 

 logical innovation. Use cluster reviews tend to be more helpful to chemical users 

 than single chemical reviews. Thus, for example, instead of looking at a single 

 chemical that happens to be a paint stripper, we are looking at a set of chemicals 

 that perform as paint strippers, to clarify what seems to be the safer material to 

 use. Like the traditional single-chemical approach, use cluster analyses can lead to 

 regulatory or voluntary action to manage risk. 



The focus of the TSCA existing chemical program on use clusters is one of the 

 intellectual underpinnings of the "Design for Environment" (DfE) program that EPA 

 has developed in the last several years. The DfE program encompasses an effort to 

 work in partnership with industries to improve their environmental performance as 

 they change technologies. The DfE projects focus on the particular choices that an 

 industry has in its operations, using information generated in a "use cluster" analy- 

 sis, in order to identify technological choices that will result in significant environ- 

 mental improvement in a cost-effective manner. 



As an example, we have been working with the dry cleaning industry to help it 

 improve its operations. This industry, predominantly small businesses, relies on 

 technologies associated with chemicals of concern, notably perchloroethylene. We 

 have worked with the industry to identify alternatives to the use of 

 perchloroethylene and to reduce the environmental impact of the chemical where it 

 is used, in the context of what the industry can afford in terms of capital invest- 

 ment. We have identified several options, including a process called "multi-stage wet 

 cleaning," that may be cost-effective approaches that can improve environmental 

 performance and maintain product quality. While further work is needed to test out 

 the viability of these technologies, this offers a promising new direction for this in- 

 dustry and a highly-valued role for the information, expertise and tools associated 

 with TSCA. 



We also envision a role for the TSCA existing chemicals program in resolving en- 

 vironmental issues that arise around particular facilities, communities or geographic 



