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ard reviews, current intelligence bulletins, updates and alerts. These data are also 

 used in developing recommended standards and associated criteria for use by OSHA 

 and MSHA in promulgating regulations. They may also be used by our research sci- 

 entists in formulating hypotheses for research. 



NIOSH is pleased that EPA has proposed the reformulation of the Toxic Release 

 Inventory to assist us in collecting information to update workplace surveys con- 

 ducted in 1971-1974 and in 1981-1983. These past surveys have been an invaluable 

 source of information used by numerous Federal programs, including the Inter- 

 agency Testing Committee, the National Toxicology Program, and NIOSH and 

 OSHA for developing regulatory, research, and testing agendas. EPA has proposed 

 a pyramid structure, with TSCA data forming the base, NIOSH interpreting the 

 data and supplementing it with industrial hygiene, medical and risk management 

 information and transmitting recommendations to the Department of Labor for reg- 

 ulatory action. This scheme, if perfected and implemented, would improve the abil- 

 ity of these agencies to protect the health and safety of workers and the general 

 public from exposure to toxic chemicals. We will continue to work with EPA and 

 OSHA on implementation of this proposal. 



One frustration with all chemical testing performed through government agencies 

 is the long lead time needed to obtain test data. It commonly requires a minimum 

 of 2-3 years before testing begins on a targeted chemical. This does not include the 

 actual test time, report writing, and review processes before the information is 

 available. We realize that streamlining this process would be extremely difficult. 



Another problem exists with the limitations on the use of confidential business 

 information either for planning research or in formulating recommendations to the 

 Department of Labor. Better guidelines need to be developed on what constitutes 

 confidential business information. 



The preventive aspects of TSCA would be greatly enhanced if industry were to 

 develop the engineering controls and protective equipment needed to assure that 

 workers are not subject to potentially harmful exposures when new chemicals are 

 introduced or when new uses or new hazards are found for existing chemicals. 



Thank you for the opportunity to describe how NIOSH uses TSCA data and to 

 suggest changes that could provide increased protection from chemical exposures for 

 workers and the general public. Mr. Chairman, I would be pleased to answer any 

 questions you or Members of your Committee may have. 



FoLLOwup Questions for Linda Rosenstock from Senator Reid 



1. At the Subcommittee's last hearing, several witnesses spoke of the need to set 

 priorities. With the large number of chemicals we have in commerce, this is crucial. 



(a) Would it be advisable for us to identify in the statute certain categories 

 or criteria for prioritizing the testing of chemicals, and if so, what categories 

 or criteria would you recommend? 



(b) How might this work with the Master Testing List? 



2. How could TSCA serve NIOSH's needs better? 



3. What do you think is the most significant limitation on NIOSH's ability to use 

 TSCA data? 



(a) What can be done to change that? 



4. From your perspective, what is the most significant chemical threat in the 

 workplace and what is being done about it? 



5. NIOSH has a representative on the Interagency Testing Committee, the ITC. 

 The ITC was intended to provide EPA with priorities for testing. However, GAO and 

 others have criticized ITC's ability to fill this role, since the process of designating 

 chemicals for EPA to test is cumbersome and does not allow EPA to set its own 

 agenda. Do you think that there is another mechanism that could provide clearer 

 direction for testing priorities? 



(a) Should developing such a list be left to EPA? 



(b) Could there be a way other than through the ITC for federal agencies to 

 advise EPA on the chemicals that should be on a testing list? 



6. Several witnesses at the Subcommittee's first hearing emphasized that a major 

 difficulty in determining the need for testing and issuing testing rules is the lack 



