161 



In my invitation to speak this morning the Committee staff asked that I try to 

 be specific to changes that I beheve would improve the effectiveness of TSCA. I will 

 attempt here to be specific, but I need to say a few words as context first. 



TSCA was drafted in the mid-1970s. We have learned a great deal in the past 

 twenty years. Our ideas about environmental protection and the role of government 

 have changed. We have a much more comprehensive understanding of the environ- 

 ment and our place in it and we have a much greater respect for the limits of effec- 

 tive government action. 



Today, we better respect the global and systemic nature of the environment. We 

 recognize that all human activity and industrial production in particular must fit 

 comfortably into the careful balances of healthy ecological systems if we are to guar- 

 antee ourselves a sustainable presence on this planet. We have learned that govern- 

 ment can not regulate all activity and that cooperative relations between productive 

 enterprises and government bodies can prove effective and economical. We have 

 learned that preventing environmental damage by correcting the cause is much 

 cheaper and more agreeable than mitigating and remediating the results of irre- 

 sponsible contamination and disruption. And we have learned that an informed pub- 

 lic can reasonably discuss technical issues and constructively participate in manag- 

 ing and planning for sound industrial development. 



I would suggest that these various lessons should guide our reconsideration of 

 TSCA. Specifically we should: 



a. work to enhance the systemic and interrelated structure of industrial activ- 

 ity and the environment, 



b. respect the limitations of government regulation and seek cooperative ini- 

 tiatives where appropriate, 



c. seek to prevent pollution and contamination rather than manage and con- 

 trol environmental disruption, and 



d. inform the public and seek to open up avenues for constructive public par- 

 ticipation in technical decision making. 



These four principles guide much of the work of the Toxics Use Reduction Insti- 

 tute. In setting priorities, conducting training or designing research projects we at- 

 tempt to see the toxic chemicals we target within the broader context of the mate- 

 rial inventory of the state economy. 



We attempt to work cooperatively with industry in identifying process changes, 

 product redesign, and material substitutions that prevent the release of toxic chemi- 

 cals into the environment. And recently we have begun to make data available to 

 the public and provide training about industrial production to the state's environ- 

 mental leaders. 



How can these principles be applied when reconsidering TSCA? Let me offer 

 twelve more specific suggestions. 



A TSCA needs to be redesigtied with a broader, more comprehensive approach to im- 

 proving the safety and soundness of chemicals in the international chemical 

 economy 



Much criticism has been leveled at TSCA for its slow and costly approach to test- 

 ing, screening and regvdating chemic^s on an individual chemical-by-chemical 

 basis. Industrial production uses thousands of chemicals as material inputs and pro- 

 duction intermediaries, including many toxic chemicals. TSCA needs a broader man- 

 date to, not only, identify and regulate problematic substances, but to support, en- 

 courage and guide industry to convert from highly dangerous chemical technologies 

 to safer systems that are more ecologically sound. Chemicals need to be considered 

 not as simple, free-standing items of concern, but, rather, within general classes of 

 substances any one of which could be used to fulfill the industrial function the tar- 

 geted chemical was designed for. TSCA needs to test and evaluate chemicals com- 

 paratively in their "use categories" and establish incentives for encouraging firms 

 to develop and convert to safer substances. 



(1) Section 8 should be modified to authorize an annual inventory of all chemicals 

 manufactured and used by industrial firms. Our capacity to adequately monitor, 

 plan for or set national policy about toxic chemicals within the broader materials 



