Summary - ACS Symposium Series (ACS Publications)

17 Summary GEORGE W. INGLE

Downloaded by RUTGERS UNIV on December 27, 2017 | http://pubs.acs.org Publication Date: May 1, 1983 | doi: 10.1021/bk-1983-0213.ch017

Chemical Manufacturers Association, Washington, DC 20037 Perhaps the major conclusion of t h i s symposium i s that there a r e so f a r no pronounced and unequivocal impacts of TSCA on s o c i e t y and the chemical i n d u s t r y . For s e v e r a l reasons, i n c l u d i n g incomplete establishment of required r e g u l a t i o n s by EPA, and the subsequent time-lags f o r compliance with these regulat i o n s , and establishment of means to monitor t h e i r e f f e c t s , f u r t h e r time will pass before these impacts will be s i g n i f i c a n t . Even f o r the long term, when all r e g u l a t i o n s will have been put in place and implemented, the complex i n t e r a c t i o n of TSCA with one or more of the twenty-odd other f e d e r a l laws concerned with c o n t r o l of chemical compounds w i l l mute the impacts of TSCA itself. It follows that the next, or third, symposium on t h i s t o p i c might best be held f i v e years l a t e r , i n 1987, rather than continue the pace of meeting roughly every two and one-half years, as was the case f o r t h i s second symposium. This i s not t o say that there have been no evident e f f e c t s . The sixteen presented papers described a wide v a r i e t y of e f f e c t s . Some of these were well documented. Still others were considered l a r g e l y s p e c u l a t i v e , awaiting the a c c r u a l of e x p e r i ence to determine t h e i r s i g n i f i c a n c e . Many of these concerns are expressed i n the last paper, given by Dr. J.C. Davies, who had much to do with the report of the 1970 C o u n c i l of Environmental Q u a l i t y . This report was the initiative which, i n turn, l e d to enactment of TSCA, s i x years l a t e r . From t h i s perspective, h i s survey of the o v e r a l l costs and b e n e f i t s of TSCA i s meaningful. Because impacts of TSCA on human health cannot be i d e n t i f i e d accurately and c e r t a i n l y not q u a n t i f i e d w e l l , and one negative e f f e c t — that on innovation i n the chemical industry, c i t e d by s e v e r a l speakers — cannot be monetized a c c u r a t e l y , only a q u a l i t a t i v e e v a l u a t i o n of TSCA is p o s s i b l e now. The costs of n o t i f y i n g new chemical substances p r i o r to t h e i r manufacture, aside from uncertainty as to EPA's requirements, were described an an impediment t o innovation. Several suggestions were made to reduce these costs by sharpening focus on the fewer h i g h e r - r i s k new chemicals and t h e i r commercialization a f t e r n o t i f i c a t i o n , and reducing concern f o r low r i s k chemicals. S i m i l a r l y , costs f o r c o l l e c t i n g the information required by TSCA need to be reduced by concentrating

0097-6156/83/0213-0225$06.00/0 © 1983 American Chemical Society

Ingle; TSCA's Impact on Society and Chemical Industry ACS Symposium Series; American Chemical Society: Washington, DC, 1983.

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on that p o r t i o n of demonstrated value. Such e v a l u a t i o n can r a r e l y be p r e c i s e . Regardless, since the question of how much r i s k w i l l be t o l e r a t e d by s o c i e t y i s more broad p o l i c y than science per se, such analyses must continue i f TSCA's implementation i s to improve and b e n e f i t s are to be optimized f o r a l l concerned i n t e r e s t s . The speakers were selected to represent views of the chemical industry and one of i t s major trade a s s o c i a t i o n s , the regulatory agency (EPA, O f f i c e of P e s t i c i d e s and Toxic Substances) , an i n t e r n a t i o n a l law f i r m and c o n s u l t i n g c o n t r a c t o r s serving industry and/or EPA, a major u n i v e r s i t y and one c e n t r a l l y p o s i t i o n e d environmental group. Thus, d i f f e r e n c e s of views were expected and were evident. As such, these views should appeal to the broad spectrum of American Chemical Society members. Eight chapters presented observations and conclusions from representatives of major chemical manufacturers, i n a d d i t i o n to a n i n t h from t h e i r trade a s s o c i a t i o n , the Chemical Manufacturers A s s o c i a t i o n . The f i r s t of these, by Nalco Chemical Company's E.H. Hurst, surveyed EPA's accomplishments and problems, and the industry's responses over the f i v e years since the e f f e c t i v e date of TSCA, January 1, 1977. TSCA's aim to f i l l the gaps among the e x i s t i n g laws c o n t r o l l i n g selected c a t e g o r i e s or uses of chemical substances, and to i d e n t i f y and e l i m i n a t e unreasonable r i s k s due to chemicals, was s t a t e d . Even more important was TSCA's "balancing" theme, to r e f l e c t economic f a c t o r s , and s o c i a l b e n e f i t s of chemicals i n reducing t h e i r r i s k s . At the same time, Congress d i d not d e f i n e "unreasonable r i s k " or seven other gradations of r i s k mentioned i n TSCA, but l e f t t h i s d i f f i c u l t task to EPA. In a d d i t i o n to summarizing very b r i e f l y the scope of each major s e c t i o n of the Act, E.H. Hurst contrasted the s e l f implementing s e c t i o n s that became e f f e c t i v e immediately and those s e c t i o n s with l a t e r timetables f o r EPA's rule-making and implementation. In the f i r s t c l a s s are Sec. 8(e), n o t i c e s of " S u b s t a n t i a l R i s k s , " and Sec. 5, "Premanufacturing N o t i c e s " of i n t e n t to manufacture or process a new chemical substances. Over 400 Sec. 8(e) n o t i c e s and some 1200 "PMN's" under Sec. 5(e) have been sent to EPA — s u b s t a n t i a l evidence of compliance. In the second category, that of rule-making by EPA, the p o i n t was made t h a t , under the Carter A d m i n i s t r a t i o n , many of these proposals were judged by industry to exceed congressional i n t e n t , and to be unworkable i n many cases, or workable but c o s t l y and i n e f f e c t i v e . One example of t h i s t h i n k i n g i s the r e s u l t i n g trend reported i n research and development — to r e s t r i c t those a c t i v i t i e s to e x i s t i n g substances to avoid the extra costs and burdens of premanufacturing n o t i f i c a t i o n of new substances. This general p o s i t i o n was analyzed i n s u b s t a n t i a l


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d e t a i l by S. Davis, Esq., who d e s c r i b e d "Chemical Industry I n i t i a t i v e s to Modify TSCA Regulations" to achieve compliance with the s t a t u t e . This account was drawn from the Chemical Manuf a c t u r e r s A s s o c i a t i o n ' s p u b l i c a t i o n , "The F i r s t Four Years of The Toxic Substances C o n t r o l Act." E.H. Hurst's overview introduced s e v e r a l themes pursued by other chemical industry speakers. The Dow Chemical Company's E.H. Blair analyzed the problem of s e t t i n g p r i o r i t i e s f o r t e s t i n g the 55,000 e x i s t i n g chemicals l i s t e d i n the TSCA inventory f o r t h e i r e f f e c t s on h e a l t h and the environment. Resources f o r such t e s t i n g are not u n l i m i t e d . A systematic c l a s s i f i c a t i o n was made of these substances by production volume. The 9.5% of these substances which account f o r 99.9% of reported production were d i v i d e d f u r t h e r i n t o c a t e g o r i e s such as organic, i n o r g a n i c , and polymeric. The commodities among these substances g e n e r a l l y have reasonably complete data f o r h e a l t h and environmental e f f e c t s , although data f o r c e r t a i n e f f e c t s may be missing. For smallervolume organic chemicals, l i t t l e or none of these data i s a v a i l able. For those chemical compounds i n use f o r decades, major h e a l t h and e c o l o g i c a l e f f e c t s would have been published had they been observed i n manufacture or use. I t was shown that the considerable t e s t i n g resources throughout the world are d e d i cated by n a t i o n a l or p r i v a t e groups to t e s t i n g those substances which would be expected to pose r i s k s to h e a l t h or to the environment. Still, in the United States, with existing screening and case-by-case s e l e c t i o n systems, such as that used by the Interagency T e s t i n g Committee e s t a b l i s h e d under TSCA's Sec. 4, i t was f o r e c a s t that f i v e to ten years of such e f f o r t w i l l be needed to f i l l adequately i d e n t i f i e d gaps i n required information. TSCA has given f u r t h e r impetus to an o r d e r l y t e s t i n g of e x i s t i n g chemical substances, l a r g e l y by t h e i r manufacturers and g e n e r a l l y on a shared-cost b a s i s . EPA's H.M. F r i b u s h showed how such e v a l u a t i o n s , and other reporting requirements of TSCA, f o r metal-working f l u i d s confirmed t h e i r contamination with tumorigenic nitrosamines. New water-based formulations, avoiding n i t r a t e rust i n h i b i t o r s and, instead, using new m u l t i f u n c t i o n a l a d d i t i v e s , consequently have been developed. This type of c o n s t r u c t i v e impact of TSCA was viewed somewhat d i f f e r e n t l y by Exxon Chemical Company's C.W. Umland. His review of nearly three years of premanufacturing n o t i f i c a t i o n c i t e d evidence which suggests s u b s t a n t i a l d i s r u p t i o n of new chemical development and i n t r o d u c t i o n to the market. This d i s r u p t i o n was traced to higher research and development costs at an economically vulnerable point i n the l i f e c y c l e of i n n o v a t i v e products. A more appropriate balance between opport u n i t y f o r economic v i a b i l i t y and p r o t e c t i o n from unreasonable


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r i s k f o r innovative chemicals i s needed. Such improved innovat i o n would be expedited by exemption from n o t i f i c a t i o n of w e l l defined, low-risk c a t e g o r i e s of new substances. E s s e n t i a l l y , the same argument was made by Muskegon Chemical Company's J.R. Yost during t h i s symposium. The smaller company frequently makes a major c o n t r i b u t i o n to the flow of new compounds, but i s a f f e c t e d d i s p r o p o r t i o n a t e l y by r e g u l a t i o n i n general, and TSCA's Sec. 5 on premanufacturing n o t i f i c a t i o n i n p a r t i c u l a r . A sharper focus on the h i g h e r - r i s k chemicals was seconded. EPA's D.G. Bannerman reviewed these impacts on the market i n t r o d u c t i o n of new chemicals. He summarized EPA's experience and analyzed the c l a s s e s and types of new chemicals, company s i z e , market areas, and, among other data, the number of n o t i f i e d chemicals a c t u a l l y reported to be commercialized. He stressed a new j o i n t industry-EPA program to a s s i s t the smaller chemical companies to comply with TSCA, e s p e c i a l l y with premanufacturing notification. This w i l l minimize negative impacts on product innovation without reducing the e f f e c t i v e n e s s of EPA's assessment of r i s k s of new chemicals. These s p e c i f i c , and other broader, concerns i n corporate compliance with TSCA's requirements were discussed by Diamond Shamrock Corporation's D. Harlow. He described how corporate s t r u c t u r e s and procedures, i n c l u d i n g those f o r research and development, f o r companies of a l l s i z e s , have been impacted by TSCA. These impacts are generally p o s i t i v e i n that they r e f l e c t g r e a t l y increased awareness, resources and responsiveness to questions of chemicals' e f f e c t s on h e a l t h and environment. These b e n e f i t s are seen to be i n balance with t h e i r costs, expressed i n the increased costs of products and s e r v i c e s . One p a r t i c u l a r area of t h i s response i s the management of information required by TSCA. Monsanto Company's C. Elmer and J.R. Condray itemized these requirements, and reviewed the status and i m p l i c a t i o n s of each. Some u n a n t i c i p a t e d b e n e f i t s derived from the mandated burden were emphasized. EPA's r e q u i r e ments f o r information are not yet complete: f u r t h e r growth i s expected. While EPA's Chemical Substances Information Network (CSIN) i s recognized as v a l i d i n concept, there i s concern that i t s scope may be expanding that o r i g i n a l l y envisioned f o r i n f o r mation submitted to EPA under TSCA. In a d d i t i o n , a t t e n t i o n must be given to the i d e n t i f i c a t i o n and maintenance of the r e l i a b i l i t y l e v e l of the information reported, stored and extracted f o r use under TSCA. One continuing problem area i n management of t h i s and s i m i l a r data required by other n a t i o n a l systems i s t h e i r c o n f i d e n t i a l i t y . Procter and Gamble's J . O ' R e i l l y presented a p e r s p e c t i v e on t h i s i s s u e , which i s d e a l t with e x p l i c i t l y by TSCA's Sec. 14 and has so f a r been managed w e l l by EPA. Problems are a r i s i n g i n


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the d i f f e r i n g treatment of c o n f i d e n t i a l i t y by other nations concerned with s i m i l a r c o n t r o l s of chemicals w i t h i n the j u r i s d i c t i o n s of the European Economic Community (EEC) and the Organisation f o r Economic Cooperation and Development(OECD). Aside from troublesome d i f f e r e n t i a l s i n concepts and procedure, there i s the concern that d e n i a l of p r o t e c t i o n of trade secrets elsewhere will weaken t h e i r security under USA laws and r e g u l a t i o n s . A proposal was made by Mr. O ' R e i l l y t o adopt some of TSCA's procedures i n other c o u n t r i e s ' r u l e s , to obtain greater uniformity i n protecting justified confidentiality worldwide. The p r o t e c t i o n of trade secrets i s only one of the d i f f e r ences among the i n c r e a s i n g number of n a t i o n a l laws c o n t r o l l i n g chemical r i s k s . B . B i l e s , Esq., described these v a r i a t i o n s among the U.S. and corresponding European laws. These laws are i n various stages of development i n compliance with the S i x t h Amendment to EEC's 1967 D i r e c t i v e on c l a s s i f y i n g , packaging and l a b e l i n g dangerous substances. The term "harmonization" i s used often to d e s c r i b e the goal of e f f o r t s to reduce these d i f f e r e n c e s and the r e s u l t i n g burden of s t i f l e d innovation, n o n - t a r i f f b a r r i e r s to i n t e r n a t i o n a l trade, and i n e f f i c i e n c i e s i n a l l o c a t i n g scarce s c i e n t i f i c , t e c h n i c a l resources of government and of the chemical industry. B i l e s opined that i t i s u n l i k e l y these d i f f e r e n c e s w i l l ever be r e c o n c i l e d by a common approach to r e g u l a t i n g new chemicals. Nor w i l l major m u l t i l a t e r a l agreements be reached on fundamental regulatory i s s u e s . Rather, accumulating experience — which i s r e l a t i v e l y short i n Europe — i n c l u d i n g responses to domestic and intra-EEC economic and p o l i t i c a l f a c t o r s , w i l l " f i n e tune" these laws through s e r i a l r e g u l a t i o n s , p o l i c y statements and a d m i n i s t r a t i v e d e c i sions. These changes may produce greater consistency. The d e s i r e f o r harmonization i t s e l f w i l l not be the primary stimulus. Meanwhile, manufacturers should plan i n i t i a l l y , e s p e c i a l l y i n n o t i f y i n g new chemicals, to comply with two or more laws, and a n t i c i p a t e o n l y a slow movement toward c o n s i s t e n c y . In a s e c t i o n on prospects f o r the f u t u r e , B i l e s ventures s e v e r a l f o r e c a s t s f o r harmonizing n o t i f i c a t i o n and other requirements over the next decade. This time frame suggests another reason f o r postponing u n t i l 1987, or l a t e r , the next ACS symposium on t h i s subject! Thus f a r , the twelve views presented have been by representatives of the chemical industry i t s e l f , or of the industry by EPA, or by an outside counsel. T h i s d i v e r s i t y i s f i t t i n g not only because of the industry's primary r e s p o n s i b i l i t i e s under TSCA, but a l s o because of the longer period of time f o r these responses to show e f f e c t s outside the i n d u s t r y . As stated e a r l i e r , the unique nature of TSCA i s i t s i n t e n t to balance the b e n e f i t s of a chemical substance with i t s adverse


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e f f e c t s on h e a l t h and environment across the spectrum of p u b l i c h e a l t h and p r i v a t e i n t e r e s t s . This purpose contrasts the goals of e a r l i e r environmental l e g i s l a t i o n to eliminate r i s k s to h e a l t h and environment, without regard to maintaining such benef i t s . Accomplishing t h i s balance of e f f e c t s has forced the continuing development of concepts and p r a c t i c e s f o r d i s t i n guishing between reasonable and unreasonable r i s k s . How w i l l EPA reach d e c i s i o n s on t h i s s c a l e , and how w i l l the industry and the p u b l i c understand and support EPA's d e c i s i o n process? To answer these and r e l a t e d questions, D e c i s i o n Focus's D.W. North described a q u a n t i t a t i v e d e c i s i o n a n a l y s i s f o r choosing among a l t e r n a t i v e s whose consequences are uncertain. This a n a l y s i s r e s t s on judgmental p r o b a b i l i t y to quantify uncert a i n t y . A f t e r reviewing the concepts of q u a n t i t a t i v e r i s k a n a l y s i s and of c o s t - b e n e f i t a n a l y s i s to show how d e c i s i o n a n a l y s i s r e l a t e s to them, an illustrative case study was presented drawn from a s p e c i f i c EPA p r o j e c t on perchloroethylene. At no point was i t a l l e g e d that such a n a l y s i s provides e a s i l y the " r i g h t " regulatory d e c i s i o n under TSCA. Complexities and u n c e r t a i n t i e s abound. What these d i s c i p l i n e s do provide i s a d e c i s i o n framework f o r i l l u m i n a t i n g these complexities and u n c e r t a i n t i e s f o r a n a l y s i s by a l l concerned i n t e r e s t s . In t h i s way, i n s i g h t s are given, with improved communication and p r o b a b i l i t y f o r consensus, more so than controversy.

The ultimate goal of such balancing of f a c t o r s and d e c i s i o n making under TSCA i s reduction of r i s k s to h e a l t h — p u b l i c and occupational — and to the environment. As mentioned e a r l i e r , because of l i m i t e d a c t i o n by EPA under TSCA, r e l a t e d to the environment (aside from restricting manufacture, use and d i s p o s a l of p o l y c h l o r i n a t e d biphenyls, banning non-essential uses of chlorofluorocarbons, and from i s s u i n g a f i n a l r u l e on d i s p o s a l of wastes of 2,3,7,8-tetrachlorodibenzo-p-dioxin), only impacts on h e a l t h were discussed, by SRI s M.J. L i p s e t t . He s t r e s s e d the p r a c t i c a l l i m i t a t i o n s on measurement of TSCA's impacts to h e a l t h . The i n a b i l i t y to i s o l a t e TSCA's e f f e c t s from those of other laws and the r e l a t i v e i n s e n s i t i v i t y of epidemol o g i c studies to long-term e f f e c t s of low l e v e l exposures are major impediments. Add to t h i s l i s t the preventive nature of TSCA. I t follows that the best i n d i c a t o r s must be estimates, extrapolated from animal t e s t s , and then with much uncertainty. 1

Regardless, i t i s concluded that TSCA may have had some indirect health effects. Manufacturers of chemicals have increased t h e i r awareness of chronic hazards i n the workplace, so t h a t occupational exposures are l i k e l y to be lower than i n the past. This greater awareness i s due not to TSCA alone, but


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to other i n f l u e n c e s such as product l i a b i l i t y l i t i g a t i o n , OSHA r e g u l a t i o n s , and p e r s i s t e n t and greater media coverage.


O v e r a l l , i t must be recognized that preventing unreasonable r i s k s i s harder to implement as a p o l i c y , and to measure as progress, than achieving percentage a i r reductions i n a i r emissions of p a r t i c u u l a r p o l l u t a n t s . This e x p l a i n s , i n p a r t , why implementation of TSCA has concentrated so f a r on gathering information rather than on c o n t r o l l i n g chemicals. At best, these comments suggest that, perhaps i n the future, there w i l l be monitoring systems s u f f i c i e n t i n number, s p e c i f i c i t y and r e l i a b i l i t y to determine i f each of the many a c t i v i t i e s generated by TSCA i s c o s t - e f f e c t i v e . I f t h i s study i s to be accomplished, there w i l l have to be new l e a d e r s h i p to manage t o x i c substances by s e l e c t i n g and i n t e g r a t i n g the s e v e r a l disciplines r e q u i r e d . UCLA's R.L. P e r r i n e proposed that an important route to t h i s i s e d u c a t i o n a l . He described a four-year d o c t o r a l program to create "environmental chemical p r o f e s s i o n a l s " t r a i n e d i n the several d i s c i p l i n e s , and i n problem solution, not merely informative research. A p p l i c a t i o n of knowledge across environmental, t e c h n i c a l and s o c i e t a l f i e l d s i s stressed i n the UCLA program, which s t a r t e d i n 1970 and now produces about s i x t e e n "Environmental Doctors" each year. This i s c l e a r l y a long-term approach. Expectations f o r the future are high. A c r i t i c a l p o l i c y question i n t h i s educational e f f o r t i s t h i s : "Where do we place the balance point i n a choice between education at the d o c t o r a l l e v e l designed to meet the needs of s o c i e t y , and education that most conveniently adapts to the needs f o r understanding and research p u b l i c a t i o n of u n i v e r s i t y faculty?" This long-term view of the costs and b e n e f i t s of TSCA, why these cannot be q u a n t i f i e d and how they may be managed b e t t e r , c h a r a c t e r i z e s the chapter by the Conservation Foundation's J.C. Davies. His c r i t i q u e of c o s t - b e n e f i t a n a l y s i s contrasts t h a t of D.W. North. Regardless, he l i s t s separately some b e n e f i t s and costs of TSCA. As to new chemicals, there i s very l i m i t e d evidence that unreasonable r i s k s may have been averted from a few new chemicals. In general, aside from systems f o r d e f i n i n g new chemicals and monitoring these, i f needed, he f i n d s no s i g n i f i c a n t b e n e f i t s i n t h i s area of TSCA. As to e x i s t i n g chemicals, while much information has been c o l l e c t e d , what i s most important i s r e a l i z i n g the need to be more s e l e c t i v e and s k i l l f u l i n c o l l e c t i n g and processing data. Section 8(e) has been a f e r t i l e source of information on subs t a n t i a l r i s k s , but only r e c e n t l y has EPA recognized the need to respond to these r i s k s . EPA's f a i l u r e to use i t s a u t h o r i t y to require industry to t e s t s e l e c t e d chemicals is similarly


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disparaged; so i s EPA's current emphasis on voluntary t e s t i n g by industry. In f a i r n e s s , however, i t i s recognized that the record w i l l show i f t h i s change i n concept w i l l be e f f e c t i v e . O v e r a l l , the narrowing of focus to concentrate on chemicals of greater r i s k i s perceived as e s s e n t i a l to s u r v i v a l under the current r e s t r i c t i o n s i n EPA's resources. No s i g n i f i c a n t b e n e f i t s are seen r e s u l t i n g from TSCA's c o n t r o l s on e x i s t i n g chemicals. D i r e c t and i n d i r e c t costs are compared; p u b l i c and p r i v a t e costs are estimated at 3.5-4 times those f o r EPA i n 1981. Among the former i s l o s s of innovation. While several studies of t h i s f a c t o r have been made f o r the industry, t h e i r r e l i a b i l i t y i s questioned, due i n part to lack of sound data p r i o r to 1976. No mention was made of economic trends a f f e c t i n g corporate expend i t u r e s f o r research and development, or of trends i n the maturation of i n d u s t r i a l chemistry i t s e l f . Other i n d i r e c t costs, such as concentration of manufacture within the industry, may result from costs of compliance, especially for smaller manufacturers. These f a c t o r s were not compared with e x t r i n s i c factors, such as s h i f t s i n feedstock supply and commodity manufacture from the United States to other c o u n t r i e s . Davies f i n d s i t impossible to determine i f the b e n e f i t s are worth the c o s t s . He suggests that i f we can agree that TSCA provides f o r p u b l i c p a r t i c i p a t i o n i n industry decision-making about chemicals, then we may be able to define ways of decreasing TSCA's c o s t - b e n e f i t r a t i o . EPA's "100 Day Report" points the way to reduce time on low-risk new substances and to improve a n a l y s i s and monitoring of h i g h - r i s k chemicals. But Davies thinks that current i n t e r p r e t a t i o n of r e g u l a t i n g e x i s t i n g chemic a l s i s unworkable, and dependence on voluntary compliance i s excessive. Unless the "due process" provided by TSCA w i l l apply equally to voluntary a c t i o n s , then the cynics who now view EPA as the "Industry P r o t e c t i o n Agency" may be r i g h t . Also, TSCA's c o s t l y a c q u i s i t i o n of information must be meshed more c l o s e l y with c o n t r o l s , under TSCA, other laws or voluntary, to obtain commensurate b e n e f i t s . The f i n a l suggestion, and p o s s i b l y l e a s t p a l a t a b l e to the ACS membership, i s to recognize that most of the c r i t i c a l quest i o n s involve more p o l i c y than science. Better science i s always needed but i t i s a p o l i c y question about how much r i s k — chemic a l or otherwise — s o c i e t y w i l l t o l e r a t e . Thus, s o c i e t y as a whole, not only s c i e n t i s t s , are e n t i t l e d to p a r t i c i p a t e i n developing the answer. The symposium ended on t h i s p h i l o s o p h i c note. Perhaps i t s sequel — i n f i v e or ten years — w i l l be able to present more d e f i n i t i v e evidence — from government, chemical industry and other sources — as to the merit of TSCA. RECEIVED

August 10,

1982


Summary - ACS Symposium Series (ACS Publications)

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