160 



submissions to EPA. For the record, I express our appreciation of EPA support in 

 developing this educational program. 



With respect to information management, we were encouraged by the publication 

 of the GAO report which examined EPA's handling of the mountain of information 

 it has collected since TSCA became law in 1976. EPA has announced its intention 

 to implement reforms recommended by the GAO report. We believe this reform ef- 

 fort is an essential part of the CBI issue. There is no justification for risking the 

 loss of our property without some benefit deriving from the action. Yet, without re- 

 forms in information management, much of the valuable information collected by 

 EPA is simply sitting in its files unused by anyone, except possibly the original col- 

 lector. EPA should pursue the data cataloging and sharing program envisioned by 

 the Congress when it enacted Section 1050 that all of EPA and its sister agencies 

 can make use of the information. 



Conclusion 



Based on our experience with TSCA Dow believes that, with some administrative 

 changes coupled with legislative clarification of some of the troublesome areas, it 

 can be an effective statute. We believe it is important to continue with risk-based 

 regulation in TSCA, to establish priorities for the wise use of increasingly limited 

 resources, especially for testing, and to avoid reducing incentives for innovation that 

 is necessary for an economically robust industry that can support the development 

 of more environmentally fiiendly new products or processes. 



Thank you for the opportunity to present our views on the implementation of 

 TSCA. We look forward to working fiirther with the Subcommittee as it continues 

 its review of the TSCA and the need for reauthorization. 



Statement of Kenneth Geiser, Director of the Toxics Use Reduction Insti- 

 tute AND THE Center for Environmentally Appropriate Materials, Univer- 

 sity OF Massachusetts, Lowell, MA 



Mr. Chairman and members of the Subcommittee, I am Dr. Kenneth Geiser, Di- 

 rector of the Toxics Use Reduction Institute at the University of Massachusetts 

 Lowell. I am here today to offer you some thoughts of mine in hopes of assisting 

 you in your reconsideration of the federal Toxics Substances Control Act (TSCA). 



As Director of the Institute at Lowell I have had the privilege of working closely 

 with professionals from several hundred industrial firms in Massachusetts who are 

 required by state law to inventory their toxic chemical use and disposal and to pre- 

 pare plans on how they would reduce or eliminate the use of over nine hundred 

 toxic substances that appear on a state priority list. 



The staff at the Institute conduct trainings for industry on toxic chemicals used 

 in industrial production and on the techniques by which those substances can be 

 evtduated and potentially reduced. In addition we sponsor and conduct research on 

 the hazards of toxic chemicals, on the development of new technologies that can re- 

 duce the use of toxic chemicals, and on new, less toxic substances that can serve 

 as substitutes for chemicals of high concern. 



I have been active in conducting research, developing policy and administering 

 programs focused on toxic chemicals for over fifteen years. Today, I serve on the 

 Core Advisory Council for the United Nation's Cleaner Production Programme and 

 as a member of the Toxics Data Reporting Subcommittee of the Environmental Pro- 

 tection Agency's National Advisory Council for Environmental Policy and Tech- 

 nology. These various roles have offered me a broad perspective on the problems of 

 toxic chemicals and the effectiveness of TSCA. 



I need not tell you that this act was hailed at its passage as one of the Nation's 

 most aggressive environmental laws and that it has never lived up to those initial 

 high expectations. Previous testimony before this Subcommittee has documented the 

 problems and limitations revealed in the Environmental Protection Agency's ("the 

 Agencjr") history of implementing TSCA. I will not attempt to summarize that testi- 

 mony here. Instead, I would like to focus on the reconsideration of the law and how 

 we might rethink this language to address some of its problems and to instill a new 

 purpose and enthusiasm in TSCA in the years ahead. 



