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CMA strongly supports EPA's efforts to screen chemicals so rational testing prior- 

 ities can be set and testing resources can be directed towards chemicals of hdgher 

 potential risk. Testing is simply not needed on every chemical to appropriately and 

 safely manage risk. CMA believes that EPA should fully utilize existing data and 

 require generation of additional information only when necessary for the evaluation 

 of human and environmental risk from a chemical of concern. 



EPA should proceed in a step-wise fashion under TSCA from screening level infor- 

 mation to progressively more complex testing. The Agency's priorities are now incor- 

 porating those identified under the internationally recognized Organization for Eco- 

 nomic Cooperation and Development (OECD) High Production Volxime (HPV) pro- 

 gram which identifies definitive testing needs through use of a Screening Informa- 

 tion Data Set (SIDS). 



CMA and its members have been strong supporters of the OECD SIDS voluntary 

 testing program from the beginning. Continuing participation in the OECD SIDS 

 program is based on CMA's position that international cooperative testing programs 

 are vital to ensure both the adequate assessment of health risks of existing chemi- 

 cals and to encourage equitable sharing of testing responsibility among producing 

 countries. The U.S. has historically conducted the predominant share of the world's 

 testing of chemicals. 



OECD's focus has been on high production volume chemicals. The OECD SIDS 

 is a standardized data set considered relevant for risk screening. Information is 

 gathered by manufacturers within the context of a prepared chemical dossier that 

 incorporates existing available data. Prescribed testing is conducted where relevant 

 existing data are unavailable. 



CMA believes the OECD focus on High Production Volume chemicals and the 

 SIDS approach to testing are good models to be considered, but there is not a rigid 

 set of tests that is suitable for every chemical. Appropriate testing for a given chem- 

 ical depends on the extent and type of exposure to the chemical, its physical prop- 

 erties, and its structure activity relationship to other chemicals with a known haz- 

 ard. 



EPA has recently initiated a negotiated rulemaking ("REG/NEG") process to de- 

 termine the best approach for amending its TSCA Inventory Update Rule. The 

 Agency has decided to expand the kind of information that is reported to EPA and 

 increase the reporting frequency fi*om every four years to every other year. CMA 

 agrees with EPA's approach to this relatively new effort. We have already volun- 

 teered to participate in the REG/NEG, which CMA believes to be an appropriate 

 and potentially valuable process. CMA also agrees that the kind of data EPA is 

 most lacking in its chemical review (Risk Management or RM) program is informa- 

 tion on uses and likely exposures. It is too early to tell if the Chemical Use Inven- 

 tory (CUI) EPA envisions will yield the kind of data needed for chemical review and 

 will be a useful tool to support risk management. CMA looks forward to working 

 with the Agency and the other stakeholders in the CUI REG/NEG process. 



Recognizing EPA's need for exposure data, CMA has been actively working with 

 EPA on the Use and Exposure Information Project. This is a voluntary initiative col- 

 lecting valuable data on chemicals that are the focus of EPA's Risk Management 

 Program. The form and process have been developed through the use of a pilot 

 project that is concluding shortly. 



CONFroENTIAL BUSINESS INFORMATION 



The protection of confidential proprietary information is an issue raised at the 

 hearing that is of critical concern to CMA and its member companies, as well as 

 other industries regulated under TSCA. For example, as H. Smith stated so clearly 

 during the hearing, protection of chemical identity is the lifeblood of the chemical 

 specialty manufacturers". Protection of specific chemical identity as confidential 

 business information (CBI) is a critical information item, and just one of many that 

 EPA protects under TSCA. 



CMA believes many of the witnesses statements at the hearing reflected both a 

 basic misunderstanding of the value of proprietary information and the scope of 

 TSCA. TSCA was not intended to be a Right to Know statute when it was enacted. 

 PubUc oversight in Section 14 of TSCA was intended to make EPA accountable for 



