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programs on the importance of and proper use of adequate safety and health equip- 

 ment. These are all preventive mandates. 



We firmly believe that preventing harmful exposures is the key to avoiding 

 human suffering and death through exposures to workplace hazards, as well as 

 "take-home" hazards that can expose family and community members. NIOSH 

 strongly supports the concept that it is the responsibility of chemical manufacturers, 

 processors and formulators to test, review, and appropriately inform users and con- 

 sumers about the hazards and proper use of their chemicals. Since the Occupational 

 Safety and Health Act does not require industry to test the chemicals it manufac- 

 tures and uses, it is through data generated under TSCA and by membership on 

 the Interagency Testing Committee, which makes recommendations to the Adminis- 

 trator of IPA on priority chemicals for rulemaking that NIOSH can obtain some of 

 the toxicity information needed for standsirds development. 



We have played an active role with the staff of IPA in implementing TSCA. 

 NIOSH has worked closely with EPA and OSHA to coordinate key policy issues re- 

 lated to toxic substances. Since becoming director of NIOSH in April, I have met 

 regularly with Dr. Ljmn Goldman, Assistant Administrator of EPA, and and Joseph 

 Dear, Assistant Secretary of Labor, on these and other issues. NIOSH activities in- 

 clude the following: 



• active membership, including chairmanship, on the Interagency Testing 

 Committee; 



• participation in EPA stewardship meetings with industry; 



• peer review of documents and participation in risk management meetings; 



• participation in the Organization for Economic Cooperation and Develop- 

 ment Screening Information Data Set (OECD/SIDS) program, which encourages 

 international coordination of testing and protocol development; 



• conducting industrial hygiene surveys through an Interagency Agreement 

 to provide EPA with exposure assessments of various industries; 



• participation in formulating the Master Testing List for the Chemical Test- 

 ing Program; 



• psu^icipation in discussions on the reformulation of the Toxic Release In- 

 ventory; 



• participation on the ONE Committee (OSHA, NIOSH, EPA, and MSHA) 

 which allows the exchange of information and risk reduction strategies, and 

 provides opportunities for coordination on health and safety issues. 



• progress toward implementation of Sections 405 and 406 of Public Law 

 102-550 (15 use 2685 and 15 USC 2686, which amended TSCA to give specific 

 responsibilities to NIOSH for lead abatement. 



Section 4 (a) of TSCA permits EPA to require the testing of any chemical which 

 may present an unreasonable risk of injury to health or the environment. In pro- 

 mulgating such a testing requirement rule, EPA may prescribe epidemiologic stud- 

 ies of employees afi^r consultation with NIOSH. NIOSH believes that the data that 

 would come from employee studies would be beneficial, and thus is eager to work 

 closely with EPA on this issue. NIOSH uses data generated from the TSCA chemical 

 testing program in many ways. For example, NIOSH used the data to assist in se- 

 lecting chemicals for developing criteria documents, including some jointly written 

 with the NORDIC Group of Experts and Swedish National Institute of Occupational 

 Health. NIOSH is pleased that the Interagency Testing Committee is recommending 

 that testing be conducted to obtain data for prevention activities, including regula- 

 tions. During the past two years, this Committee has evaluated the need for 

 percutaneous absorption data that could be used by NIOSH, OSHA, MSHA and oth- 

 ers to further control worker skin exposure. These kinds of data will play a signifi- 

 cant role in the current efforts by NIOSH and OSHA to jointly develop priorities 

 for regulatory and other prevention activities. 



NIOSH also uses TSCA data in compiling the Congressionally mandated NIOSH 

 data base known as the Registry of Toxic Effects of Chemical Substances (RTECS). 

 This data base is used internationally in a variety of formats to identify toxic effects 

 of over 123,000 chemicals. TSCA data are used by NIOSH to develop documents for 

 informing employers and employees about workplace hazards through special haz- 



