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stakeholders in the manufacturing sector and user community, and these stakehold- 

 ers must be part of any hearings on TSCA. 



CMA wishes to highlight and respond to the most critical issues raised during the 

 hearing. For some of these issues, CMA's views are already on the record with the 

 Environmental Protection Agency (EPA) and with other Senate and House Commit- 

 tees. CMA believes it is useful to repeat our views here and place them in the prop- 

 er context for this hearing record. 



The most critical issues raised at the hearing from our perspective were: existing 

 chemical review; data on chemicals in commerce; confidential business information; 

 and, pollution prevention. 



EXISTING CHEMICAL REVIEW 



The overall focus of the hearing was the review of chemicals in commerce under 

 TSCA. Our industry is committed to protecting health, safety, and the environment 

 in a manner that yields the greatest protection possible for the amount of resources 

 used, by setting priorities for action based on the risk posed. CMA and its members 

 are committed not just to the mandates of TSCA but also to responsible manage- 

 ment of risks and the stewardship of our industry's products throughout their life 

 cycle. 



EPA, like CMA, recognizes that not all chemicals or uses of chemicals present sig- 

 nificant risk. EPA has acknowledged the need to set risk-based priorities, taking 

 into account the amount of exposure as well as intrinsic hazard. Chemical review 

 under TSCA is intended to be prioritized by risk. CMA believes that risk is very 

 often associated with the application or use of a chemical. Even though knowledge 

 of a chemical's use is not always a surrogate for exposure or risk, it does guide our 

 industry's product assessments and assists EPA in its own prioritization efforts 

 under TSCA. 



CMA supports risk-based priorities and cost-effective risk management decisions. 

 CMA member companies utilize a variety of risk assessment techniques to help set 

 their own priorities, goals, and plans for responsible product stewardship and envi- 

 ronmental protection. For example, under CMA's Responsible Cared Pollution Pre- 

 vention Code, member companies establish priorities, goals, and plans for waste and 

 release reduction based partly on an assessment of relative risk and partly on over- 

 all community and employee concerns. Similarly, CMA's Product Stewardship Code 

 requires companies to characterize new and existing products with respect to their 

 risk, taking into account information about potential hazards and reasonably fore- 

 seeable exposures. These are then used to determine appropriate risk management 

 activities. Risk assessment and relative risk analyses have an important role to play 

 in the private sector, as well as at the governmental level. 



DATA ON CHEMICALS IN COMMERCE 



Two concerns were raised at the July 13, 1994 hearing that focused on the data 

 available on chemicals in commerce. Many of the witnesses asserted that not 

 enough chemicals have been tested and that more and better data must be available 

 to EPA to evaluate potential risks from chemicals. 



Lynn Goldman, Assistant Administrator for EPA, stated in her testimony that . 

 . . "[a]s a direct result of years of chemical screening efforts, OPPT has determined 

 that its efforts to identify candidates for testing or risk assessment should focus pri- 

 marily on the approximate 14,000 non-polymeric TSCA Inventory chemicals that are 

 produced at levels of over 10,000 pounds per year. . . " (EPA Statement of L. Gold- 

 man at p. 3). 



EPA has used hazard-based and exposure-based screening techniques to identify 

 priority testing candidates from this subset. EPA's testing agenda traditionally was 

 identified through designation by the Interagency Testing Committee or by receipt 

 of "substantial risk" information through the TSCA Section 8(e) program. EPA also 

 receives requests for testing from other program offices within EPA such as the 

 Hazardous Air Pollutants (HAPS) Section 4 test rules that the Agency is currently 

 developing to satisfy Clean Air Act requirements. 



