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tion volume. Based on our recognition of this concern, Dow was sunong those that 

 lead in the development of the OECD High Production Volume (HPV) voluntary 

 testing program. The HPV program had several objectives. First, to develop a set 

 of relatively inexpensive, short term tests that would predict the need for more de- 

 finitive testing. This objective has been realized for most, but not all, toxic endpoints 

 of concern. The group of tests, actually endpoints, are collectively called the Screen- 

 ing Information Data Set or SIDS. Second, to screen high production volume chemi- 

 cals with global potential for significant exposure using SIDS. This objective is in 

 progress. Third, to establish a program which more equitably shares the economic 

 burden of testing among the developed nations comprising OECD, and allows the 

 US chemical industry to complete on a more even footing with our foreign competi- 

 tors. We count the OECD HPV voluntary testing program a major success. 



Dow, in common with other US chemical producers, believes that the success of 

 the HPV program justifies its application in TSCA-driven testing programs for exist- 

 ing chemicals. That is, we believe that no comprehensive testing program should be 

 imposed on a chemical before the information encompassed by the SIDS is assem- 

 bled or generated and evaluated. Such a process would better focus the definitive 

 data needs for the chemical of concern, allowing both industry and EPA to allocate 

 scarce resources to generating the highest priority data needs. Dow believes the suc- 

 cess of this voluntary program is indicative of industry's increasing acceptance of 

 the need for more extensive testing of its products when the need has been dem- 

 onstrated by review of the information available for these products. 



In addition to the HPV program, other voluntary or cooperative programs are in 

 process, most generating definitive data, rather than screening information. We be- 

 lieve that these non-regulatory testing programs conserve resources required to de- 

 velop test rules under Section 4 of TSCA. The Subcommittee has also been made 

 aware, I believe, of testing underway in other nations, primarily the European 

 Union, and Japan. Although admittedly slow in starting, an extensive, global effort 

 to gather needed test data for significant numbers of chemicals is underway. 



This global effort has given rise to a new set of issues of which the Subcommittee 

 shovild be aware. As the amount of testing underway increases, the capacity for con- 

 duct of additional testing begins to be limited. For example, EPA is in the process 

 of developing a comprehensive testing program under TSCA to support the need for 

 residual risk determinations for Hazardous Air Pollutants required under the 

 amended Clean Air Act. As industry reviews this developing initiative, there is 

 growing concern that insufficient testing resources are available for its conduct. 



Our nation's limited testing resources are also needed for testing which supports 

 other requirements, including new product development. And, Mr. Chairman, the 

 only source for new, more environmentally friendly chemicals, or processes which 

 support pollution prevention, is in the chemical industry, so new product and proc- 

 ess development is critical in reducing risks from chemicals. 



Because our ability to "protect" the intellectual property interest in health or envi- 

 ronmental data that results from testing programs is almost nonexistent, except 

 under FIFRA, our competitors abroad benefit from the testing we do in the U.S. At 

 the same time, we are experiencing problems in obtaining full studies fi-om some 

 other nations under the HPV program. Again, we seem not to be playing on a level 

 field. Finally, there is a need for global acceptance of data developed using any rea- 

 sonable protocol. Lack of mutual acceptance of data between nations often requires 

 duplicative testing, a waste of resources that could better be used elsewhere, and, 

 in the face of limited resources, a dela)dng factor in developing needed data. 



Dow believes that a requirement to develop a standard test data set for all chemi- 

 cals using a check-the-box approach is counterproductive because it ignores expo- 

 sure, or other factors which are part of the priority setting process. 



Exposure Data 



Exposure information is a key element in setting priorities for both testing and 

 control, because it is determinative of risk. Gross estimates of exposure are rel- 

 atively easy to obtain, mainly because simplifying, and usually false, presumptions 

 are made. For example, production volume is often used as a surrogate for exposure, 

 but this can lead to gross errors. For example, the huge U.S. production volume for 



