153 



Establish Goals and Priorities 



To put the existing chemicals program on a more equal footing with new chemical 

 review, TSCA could be revised to set some specific deadlines or targets for the re- 

 view of existing chemicals. Providing such a goal would establish a clear national 

 policy and focus EPA's and the chemical industry's efforts on completing the re- 

 views. 



However, even with such a goal, it would likely take many years to review the 

 large number of chemicals that comprise the TSCA inventory. Thus, some means 

 of setting priorities would be necessary to ensvu-e that risks to health and the envi- 

 ronment are addressed in an appropriate and timely manner. According to EPA, 

 only about 16,700, or 23 percent, of the 72,000 chemicals in the TSCA inventory are 

 of concern because of their production levels or chemical structure. This number is 

 still large, and EPA would need flexibility to focus the agency's and the industry's 

 resources on those chemicals that, based on their toxicity, production volumes, and 

 potential exposure, present the highest risk to human health and the environment. 

 This could be accomplished by setting out chemical review priorities in TSCA or by 

 requiring EPA to implement a process to develop such priorities. 



Other industrial countries have recognized the importance of systematically re- 

 viewing their existing chemicals. A 1993 European Union directive, for example, re- 

 quires member countries to participate in a systematic review process for existing 

 chemicals. The European Union plans to focus at first on high production chemicals 

 and to periodically develop priority lists of chemicals for member countries to re- 

 view. 



Shift Some of the Burden to Industry 



Although establishing priorities would help EPA to focus its efforts on the most 

 serious chemical risks, the agency still may not be able to substantially improve its 

 performance in reviewing the thousands of chemicals in use without shifting to the 

 chemical industry more of the burden and cost for developing and compiling data. 

 EPA now is responsible for compiling and analyzing the available information on 

 chemicals' effects and exposures. Because few data — especially on exposures — are 

 often available, EPA uses various models to project or estimate information, such 

 as the amounts and types of exposures. The agency has to issue rules to require 

 testing or to collect additional exposure information from industry. A rule to require 

 testing of a chemical can take as long as 24 to 30 months and cost from $68,500 

 to $234,000. 



One way to shift some of the responsibility to industry would be to revise TSCA 

 to require chemical manufacturers to compile available data on chemicals and sub- 

 mit the results to EPA, as they now do for new chemicals. Under this approach, 

 EPA would identify the types of information required and the reporting format. The 

 agency would also notify the industry in advance of the priority chemicals scheduled 

 for the agenc/s review within a certain period and the dates when it must submit 

 the information to EPA. EPA would review the information and inform industry of 

 the additional data needed. The 1993 European Community directive requires man- 

 ufacturers to compile and report certain data on existing chemicals to member coun- 

 tries. 



Another option would be for EPA to continue to be responsible for compiling avail- 

 able information, reljdng primarily on information in its files and in publicly avail- 

 able data bases. EPA coiild be authorized to more easily obtain information from 

 industry to fill gaps in the data needed to perform assessments of chemical risks. 

 Authorizing EPA to obtain the additional data without having to issue rules, as it 

 is now required to do, could substantially reduce the resources that the agency uses 

 for this purpose. This authority could be limited to chemicals that, at the time, are 

 in the process of being reviewed and to the specific data needed to complete assess- 

 ments of these chemicals's risks. TSCA could also be revised to make it easier for 

 EPA to issue these rules. For example, to issue a test rule, EPA must currently 

 demonstrate that insufficient data exist and a chemical may present an unreason- 

 able risk or that significant exposure may occur. Allowing EPA to issue a rule solely 

 on the basis that the information is needed to assess the chemical's risks would re- 

 quire less supporting evidence for the rule. 



