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of information on toxic chemicals and public involvement is an essential element of 

 the Act. 



Statement of Hugh M. Smith, Synthetic Organic Chemical Manufacturers 



Association (SOCMA 



The Synthetic Organic Chemical Manufacturers Association (SOCMA) appreciates 

 the opportunity to submit this written statement to the Senate Committee on Envi- 

 ronment and Public Works Subcommittee on Toxic Substances, Research and Devel- 

 opment. SOCMA is a trade association serving more than 225 companies that have 

 a common interest in the manufacture, distribution and marketing of organic chemi- 

 cal products. These products are used to manufacture a wide variety of substances 

 including pharmaceuticals, paints, inks, adhesives, agricultural specialties, cosmet- 

 ics, soaps, plastics, processed foods and textiles. 



The majority of SOCMA's members are small specialty chemical manufacturers 

 with annual sales under $40 million, most of which are subject to the reporting re- 

 quirements under the Toxic Substances Control Act (TSCA). Many of SOCMA's larg- 

 er member companies have small specialty chemical operations that face many of 

 the same regulatory challenges as small specialty chemical companies. SOCMA 

 member companies typically with 50 or fewer employees, are representative of the 

 universe of synthetic organic chemical manufacturers throughout the United States. 



As the major trade association in Washington addressing the concerns of specialty 

 chemical operations, SOCMA's TSCA activities are structured so as not to duplicate 

 those of other chemical industry trade associations. SOCMA's primary goals are to 

 advocate the needs of specialty chemical operations and to ensure that SOCMA 

 member companies have access to compliance and performance improvement infor- 

 mation. 



SOCMA is a Partner Association in the Responsible Care initiative, a program de- 

 veloped by the Chemical Manufacturers Association (CMA) to improve the chemical 

 industry's environmental, safety and health performance. In partnering with CMA, 

 SOCMA seeks to facilitate the ability of its smaller member companies to partici- 

 pate in the initiative and thereby improve the performance of their operations. 

 SOCMA is now providing comprehensive Responsible Care implementation assist- 

 ance to its nearly 90 non-CMA member companies, which are primarily small spe- 

 cialty chemical companies. SOCMA is also participating on CMA's Responsible Care 

 Partnership Advisory Council. 



SOCMA Supports Several of OPPTs Current Initiatives Under the Existing Chemi- 

 cals Program 



EPA's Office of Pollution Prevention & Toxics (OPPT) is cvurently implementing 

 new "initiatives" which were developed to improve the Existing Chemicals Program. 

 SOCMA supports several of these initiatives, particularly those that are concep- 

 tually similar to the chemical industry's goals for performance improvement. Many 

 of EPA's new approaches for existing chemicals are the result of an OPPT "revital- 

 ization" undertaken to make Existing Chemicals Program activities more action-ori- 

 ented and risk-based. Among these major OPPT initiatives are: the Master Testing 

 List, the Use Cluster Scoring System and the Risk Management Program. Further 

 strengthening OPPT's Existing Chemicals Program is EPA's commitment to adopt 

 a pollution prevention "ethic" in all media-specific programs as mandated by the 

 1990 Pollution Prevention Act (PPA) and its recognition that public empowerment 

 is important. 



SOCMA is particularly supportive of OPPT's Risk Management (RM) program, a 

 tiered review and decisionmaking process by which EPA identifies potential risks 

 (from the universe of existing chemicals) and implements "targeted" risk reduction 

 measures as warranted. SOCMA agrees that EPA should assess and subsequently 

 manage risks in this manner. SOCMA believes that further coordination with other 

 agencies could improve the RM process and allow federal agencies to exchange infor- 

 mation and identify risk reduction opportunities. For example, to the extent that a 

 chemical poses a workplace hazard, SOCMA believes that EPA generally should 



