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Mr. Hucues. That was not my point. EPA has established what 
is a safe level for things such as cadmium and mercury and we 
know that in the New York Bight in the instance of mercury, I be- 
lieve it is now 100 times EPA’s established safety level. 
We know that that is not being assimilated, do we not? 
Ms. Hurp. In our proposed regulations, our position in the 
London Dumping Convention, also controls the amount of cadmium 
to trace amounts for any disposal in the ocean. 
Mr. HuGues. My time is up. I recognize that. I just want to echo 
what my colleague from Delaware has said. I always thought that 
the Congress developed policy but in 7 years I have learned one 
thing, we do not develop policy, we think we do. We now have the 
tail wagging the dog, in essence. In the failure to appeal the Sofaer 
decision, the failure to carry out what was the clear intent of the 
Congress by the EPA which I just think is an absolute violation of 
responsibilities under the law. 
I agree with my colleague from Delaware and I just regret that 
we have decided to retreat for the sake of convenience and cost on 
what I think is good ocean policy. 
Thank you. 
Mr. D’Amours. The gentleman from Washington, Mr. Pritchard. 
Mr. PritcHarD. Mr. Chairman, I yield to the gentleman from 
New York. 
Mr. Carney. Thank you, Mr. Pritchard. 
I would like to ask Ms. Hurd, is there any comprehensive pro- 
gram designed now, using the three agencies that are involved in 
ocean dumping to study the three different methods of getting rid 
of sludge? And, if so, who is going to take the lead role? 
Ms. Hurp. There is a major effort within the EPA at this time to 
develop a comprehensive sludge policy looking at all disposal 
media. In the appropriate areas we are coordinating, not only with 
NOAA in the ocean disposal area, but also with the Department of 
Agriculture and FDA on land disposal. 
Mr. Carney. OK. You are evaluating the problem from the 
standpoint of looking at the three different options? 
Ms. Hurp. Yes. 
Mr. Carney. And you are again coordinating the efforts within 
all agencies to do precisely this? 
Ms. Hupp. Yes. 
Mr. Carney. Do you have a time frame so we might be able to 
have some type of preliminary report as to the progress? 
Ms. Hurp. We have a work plan and at this point in time we are 
talking about an initial proposal by the end of this year, January 1. 
Mr. Carney. And what would the initial proposal entail? 
Ms. Hurp. Basically to look at the risk assessment of disposal in 
all three media, to look at the technology, to look at the adminis- 
trative feasibility of managing sludge in all three areas, and to 
come up with a set of guidelines on how best to manage in each 
area. 
Mr. Carney. Keeping that in mind, you said that within a year 
we will have some sort of direction—— 
Ms. Hurp. We probably will not answer all questions; we will do 
a major cut. 
