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CMA believes that TUR initiatives, regardless of their name, are contrary to the 

 risk-based and pollution prevention principles we support. TUR is not risk-based. 

 It requires use reduction regardless of the nature and degree of risk posed, the ben- 

 efits of the chemical, or the increased risks associated with reducing or eliminating 

 use, including the risk substitutes might pose. Moreover, TUR is a serious threat 

 to the ability of U.S. industry to compete in the world marketplace. 



TUR initiatives are totally inappropriate in Section 6 of TSCA. Section 6 is trig- 

 gered by an "unreasonable risk" standard, requires use of the least burdensome reg- 

 ulation, consideration of the economic consequences and the availability of sub- 

 stitutes. That section contains a range of risk management options including warn- 

 ing labels, disposal restrictions, customer notice, quality-control procedures, and lim- 

 its on the amount or use of a chemical. EPA has not used its Section 6 authority 

 frequently. We believe it is appropriate that Section 6 of TSCA has been used infre- 

 quently since TSCA is most often used to fill regulatory gaps not covered by other 

 environmental statutes. Careful review of the existing authority in Section 6 of the 

 statute is needed. Pollution prevention may be further considered, but should be 

 based on well accepted risk-reduction principles. 



CMA appreciates this opportunity to submit these comments to the hearing 

 record. Thank you. 



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