Document nk4x5vvQr60g96DqKeveyM8qR

SYNTHETIC ORGANIC CHEMICAL MANUFACTURERS ASSOCIATION . TOTS CENTRAL PARK AVENUE. SCARSDALE, N.Y. 10583 (914) 725-H92 July 6, 1973 TO: ENVIRONMENTAL BOARD OF GOVEB Gentlemen: It6 version of the Toxic Substances Control Act (S. 426) and the House Interstate and Foreign Commerce Committee's June 29th Report on Its bill (H.R. 5356) together vlth a memorandum discussing the key provisions of these bills. Tlje^House bill, as reported. Is a touch piece nf laninlnHnn- and would add And the full House Committee did modify the bill to reflect concerns expressed about the Subcommittee's Intent In Including mixtures In the legislation and, in part, the relationship of this bill to other environmental legislation. The focus of the Senate bill's testing requirements has been sharpened some what to chemicals which have the potential forenvirbnmental Harm. Howevgr~the Senate bill still has sweeping requirements tor premarket screening. Of particular concern Is the pi-rviHc-lnn fnr up to 180-day premarket screening period for chemicals for Which- there has bpen tin fjndinp of potential danger and no requirement for testing. During this period EPA7~without public hearing or comment, can Impose binding restrictions on the use of new chemicals or new uses on the basis of an absence of data. ', There Is even a substantial question as to whether such decisions are subject to judicial review. The Senate bill also has shortcomings with respect to avoiding duplication with other laws. - SOCMA has proposed amendments to a Manufacturing Chemists Association Task Force (1) for dealing with the problems of-EPA's authority to restrict chemicals In the absence of data or at least (2) to ensure: judicial review of such actions and (3) for strengthening the provision against duplication of other environmental laws. The MCA group is reviewing the possibilities for action. It is also assessing the need for action to defend the House bill against floor attempts to eliminate carefully considered measures"to minimize unnecessary testing and regulation. . -r i o He will keep you Informed of developments. Sincerely, > IA O Encs. l TOWOLDMONOQ55462