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economy is dramatically constrained by the absence of a national data base docu- 

 menting the manufacture, distribution, and use of toxic chemicals and their poten- 

 tial substitutes. Vast amounts of synthetic materials move around the country, but 

 their uses and flows can only be estimated by targeted surveys or computer models. 

 The Agency has more data on chemicals as wastes than it does on chemicals in com- 

 merce or chemicals as manufactured or imported commodities. The chemical use 

 data collected in Massachusetts suggests that far greater volumes of toxic chemicals 

 are produced as products than released as wastes. Currently the Agency collects 

 some chemical production data under its Inventory Update Rule, but this is limited 

 to organic chemicals and is collected only every four year. The Agency is considering 

 expanding its data collection under a Chemical Use Inventory. This should be en- 

 couraged in the redrafting of Section 8. 



(2) Section 12 should be broadened to establish an international clearinghouse for 

 the collection, dissemination and coordination of information on toxic chemicals in 

 international trade. The Agency should work cooperatively with other nations to es- 

 tablish an international clearinghouse of toxic chemical data. Firms seeking to buy 

 or sell chemicals internationally should be required to enter into this central clear- 

 inghouse all non-confidential TSCA data on the toxicology, environmental and 

 health effects and other scientific knowledge available on those chemicals. Such a 

 clearinghouse would assist domestic firms in adequately assessing the potential haz- 

 ards of chemicals prior to importation and would centralize the authority for provid- 

 ing other governments and international firms information on domestically produced 

 chemicals. 



(3) Section 4 should be redesigned to reduce the focus on individual chemical and 

 to promote the testing and evaluation of chemicals within "use categories". While 

 there will continue to be a need for individual study of particular chemicals of high 

 concern or of unknown effects, the Agency's initiatives toward evaluating chemicals 

 comparatively within "use categories" needs to be promoted and legitimated with 

 statutory language. Such "use category" assessments focus less on the risk charac- 

 teristics of individual chemicals and more on the comparative risk of alternative 

 chemicals in order to assess which substances offer the highest degree of safety. We 

 find in Massachusetts that this use approach to chemicfd assessment better approxi- 

 mates the way in which industry makes decisions and presents information in a 

 manner that more effectively assists firms in making decisions that reduce risk. 



(4) A new section should be added to TSCA to encourage the development and 

 use of safer and more ecologically sound chemicals and technologies. The Agen- 

 cy should identify chemicals of high concern, for which alternative substitutes 

 should be selected or, where none exist, developed. The Agency should establish 

 special programs for promoting safer chemicals and working with industry in 

 converting to safer and sounder technologies. These programs should include 

 both research and technical assistance and should be designed to support cur- 

 rent state efforts. 



B. TSCA needs to be redesigned to maximize industry cooperation in evaluating and 

 managing chemical substances and to more equitably shift the burden of respon- 

 sible chemical management to industry 



For years the Agency has been lagging in its expected rate of chemical testing and 

 only recently has the Agency turned to voluntary testing programs and consent 

 agreements to facilitate more rapid chemical evaluation. But, even these programs 

 have moved slowly. With thousands of chemical substances in need of testing and 

 proper testing requiring significant time and resources, it is clear that the Agency 

 must rely on industry and share the burden more effectively with other nations. 



(5) The requirements on firms for supplying a comprehensive packet of test re- 

 sults on toxic chemicals of high concern needs to be expanded and streamlined in 

 Section 4. Section 4 needs to be rewritten to provide more authority to the Agency 

 for requiring industry to test and for providing more positive incentives for encour- 

 aging industry to voluntarily test. Firms wishing to introduce new chemicals to the 

 economy are currently required to produce sufficient scientific data for Agency eval- 

 uation. While these requirements yet need more clarification, the Agency has no 



