-f FT TSCA
Chemicals-in-Progress
Bulletin
.,C4.
'
Sail
i
Office of Pesticides & Toxic Substances
Vol.2, No. 1
JANUARY 1981
This bi-monthly news bulletin is intended to inform all persons concerned with the
Toxic Substances Control Act (TSCA) about recent developments and near-term
plans. For further information or to request copies of documents mentioned, write
the Industry Assistance Office (IAO), (TS-799) OPTS, U.S.E.P.A., Washington, D.C.,
20460 or call toll-free 800-424-9065 or, in Washington, D.C., 554-1404.
REGULATORY & REQUIRED ACTIONS
PREMANUFACTURE NOTIFICATION (PMN)...
SECTION 5
Under Section 5
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Generic name: Ethene-alkene-vinyl carbonyl amine polymer
Generic name: Polyurethane polyacrylic polymer .
N.(2.Hydroxypropyl)-N.tris(5-hydroxy2-OxO-PefltYl) ammon-
urn acetate
22,4-trimethyl-1 ,3-pentanediol. trimethylolpropane, succinic
anhydride, trimellitic anhydride, adipic acid and isophtha-
tic acid
1 -Nitronaphthalene-6-sulfonic acid, potassium salt
1-Nitronaphthalene-7-sulfonic acid, potassium salt
Generic name: Disubstituted heptadecane
Generic name: Aliphatic diol
Azelaic acid. 1,4-cyclohexanedimethanol dimer acid, dime-
thylol propionic acid. methylene-bis (4-cyclohexyl isocya-
nate). neopentyl glycol, trimethylol propane polymer
Generic name: Atiphatic polyurethane water-borne disper-
sion
Propylene glycol, ethylene glycol terephthalic acid polymer,
phthalic anhydride and maleic anhydride
Generic name: Carbomonocycl Ic. carbopolycycl ic poyester - -
Generic name: Acryloxyethyl heteromonocycle
Coconut fatty acids, benzoic acid, isophtalic acid. neopentyl
glycol, propylene glycol
Generic name: Dimer fatty acid polyamide
1-Octanamine, N, N-dimethyl-. phosphate salt
Generic name: MethylaziridinylcarbonyliminO oleyl trilmido
diisophorone poly(propylene glycol)
Generic name: Unsaturated branched chain hydrocarbon
having 10 carbon atoms
Generic name: Unsaturated branched cha;n ketone having 12
carbon atoms
Generic name: Neutralized polymer of styrene, alkyl acry-
lates and substituted alkyl methacrylates
Polymer of palm oil, coconut oil, pentaerythritol, benzoic
acid, phthalic anhydride and maleic anhydride
Generic name: Fatty acids, esters with polyols
Linseed oil, styrene, glycerine. toluene dilsocyanate
Benzenamine, [ N-(1-methylhexyl idene)-N’-(l -methyl butyli-
dene)-4,4’-methylene bisj
Generic name: Di (substituted al kyl) carbomonocycl icdicar-
boxylate
Generic name: Polymer of alkanedioic acids, 2-ethyl-2-(hyd-
roxymethyl)-1 ,3-propanediol, 2 .2-dimethyl-1 ,3-propanediol
Generic name: Substituted phenol, reaction products with
sulfur chloride
Generic name: Esterif led polyamic acid
Generic name: Dineoalkyl ester of glycerine
Polymer of glycidyl methacrylate, hydroxy propyl methacry-
late, 12-hydroxystearic acid, methacrylic acid, methyl
methacrylate polymer
45 FR 65030
10/1/80
45 FR 63345
9/24/80
45 FR 64245
9/29/80
45 FR 65033
10/1/80
45 FR 65029
10/1/80
45 FR 65029
10/1/80
45 FR 65032
10/1/80
45 FR 65032
10/1/80
45 FR 65033
10/1/80
45 FR 65034
10/1/80
45 FR 65664
10/3/80
In prep.
45 FR 67449
10/10/80
45 FR 67450
10/1 0180
45 FR 67450
10/10/80
in prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
45 FR 16006
3/12/80
45 FR 15644
3/11/80
45 FIR 24696
4/10/80
80-240
80.241
80.242
80-243
80-244
80-245
80-246
80-247
80.248
80-249
80-250
80-251
80-252
80.253
80-254
80.255
80-256
80-257
80-258
80.260
80-261
80.262
80-263
80-264
80-265
80-266
80-267
80-268
80-269
80-270
12/1/80
12/3/80
12/4/80
12/7/80
12/7/80
12/7/80
12/7/80
12/7/80
12/8/80
12/9/80
12/11/80
12/11/80
12/15/80
12/15/80
12/15/80
12/16/80
12/17/80
12/17/80
12/17/80
12/18/80
12/21/80
12/21/80
12/22/80
12/25180
12/25180
12125/80
12/28/80
12/28180
12/28/80
12/28/80
PMN No.
New Chemical Substances that EPA Has Added to the Inventory During the Month
Submitter Chemical Identification
FR Citation
80-23 Grow Group Polymer of Epichlorohydrinbis A; bisphenol A; -methyl
Inc. morpholine and acetic acid
80-31 Claimed confiden- Generic name: chloroorganoaminofluoran dye
tiaI business
information
CBI
80-57 Sun Petroleum Generic name: Alkyl biphenyls
Products Co.
2
-------
Generic name: Sulfonic acid salt of ureylenebis-(hydro-
(xy - (sulfo-naphtyl)azOflmaphthalene
Generic name: Sulfonic acid of a ureylene bis(ydroxy-
[ (sulfo-naphthyl)azo napthater1e compound
Polymer of 12 Hydroxy stearic acid and epoxy resin
Generic name: Polyester reaction product with isophcr-
one dilsocyanate and hydroxypropyl acrylate
Generic name: Cyanalkyl carbomonocylicsulfonate
(Added August 1980>
OCTOBER 1980 PMN STATUS REPORT
80-302
80-303
80-304
80-305
N-Methyl-N-glucitylstearoylamide
Amines. C 10-16 alkyl dimethyl, phosphate salt
Polymer of tall oil fatty acid, isophthalic acid. trimethylol
propane, trimel I itic anhydride, methyl methacrylate. ethyl
acrylate, methacrylic acid, hydroxy ethyl methacrylate
Generic name: Styrene acrylic polymer
Generic name: Modified terpolymer of mixed alkyl acrylates
Generic name: Modified copolymer of mixed alkyl acrylates
Polymer of 2,2-dimethyl 1 ,3-propanediol; 2,2,4-tn methyl 1,3-
pentanedial; isophthalic acid and fumaric acid
Generic name: Hydrogen zeolites
Polymer of Propylene glycol, neopentyl glycol, isophthalic
acid, Empol 1022 dimenic fatty acid, trimellitic anhydride
polymer
Aminoalkanol salt, as a 25 percent aqueous solution
Generic name: Styrene methacrylate acrylate polymer
Generic name: Polymer of alkanediols and carbomonocylic
anhydrides
N(4-Diazo phenyl) morpholine hexafluorophosphate
Polymer of tall oil fatty acid, isophthalic acid. terephthalic
acid, pentaerythritol, benzoic acid and trimethylol propane
Polymer of soybean oil. pentaerythritol, isophthalic acid.
benzoic acid, terephthalic acid
Amines, isopropyl, distillation residues
Amines. ethyl, distillation residues
Polymer of epoxy resin, bisphenol A, paraformaldehyde, di-
butylamine and diethanolamine
Generic name: Disubstituted carbopolycyclic derivative
Generic name: Dimethyl alkylmethyl silicone glycol copoly-
mer
Generic name: Siloxane, alkoxylated aminoalkyl
Generic name: Disubstitutednitrobenzene
Generic name: Ethyl, substituted, (((sulfopropyl) heteropoly-
cyclic)methyl)alkenyl heteropolycycle
Generic name: Ethyl, substituted, methylheteropolycycle
tosylate
Generic name: Substituted, methylbeteropolycycle
Generic name: Disubstituted benzene
Generic name: Bis(Nitro, substituted phenyl) substituent.
Cyclohexane, 1,1 -methylene bis [ 4-isocyariato-, reaction
products with 1,3-isobenzofurandione, polymer with
1,6-hexariediol, alpha-hydro-omega-hydroxYPolYOxY
I1.4-butane-diyll and (2-hydroxyethyla-2-propenoate
Generic name: Modified polyester based on carbomonocyclic
anhydride and alkanediols
Generic name: Substituted alkyl peroxycarbonate
Generic name: Alkyl substituted chlorocarbonic acid
Generic name: Polyurethane thermoplastrics
45 FR 73128
11/4/80
45 FR 73128
11/4/80
45 FR 73132
11/4/80
45 FR 71415
10/28/80
45 FR 71415
10126/80
45 FR 71415
10/28/80
45 FR 73128
11/4/80
45 FR 74562
11/10/80
45 FR 73131
11/4/80
45 FR 75752
11/1 7/80
45 FR 74993
11/13/80
45 FR 75752
11/17/80
45 FR 74993
li/i 3/80
In prep.
In prep.
45 FR 75750
11/17/80
45 FR 75750
11/17/80
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
In prep.
80-70 CBI
80-71 CBI
80-75 CBI
80-84 CBI
80-88 CibaGeigy
Corp.
45 FR 27006
4/24/80
45 FR 24696
4/10/80
45 FR 30127
5/7/80
45 FR 30132
5/7/80
45 FR 32772
5/19/80
PMN No. Identity/Generic Name FR Cita’ion Expiration
Date
Premanufacture Notices Received during the Month
80-272
80-273
80-275
80-276
80-277
80-278
80-279
80-280
80-281
80-282
80-283
80-284
80-286
80-287
80-288
80-289
80-290
80-291
80-292
80-293
80-294
80-295
80-296
80-297
80-298
80-299
80-300
80-301
1/1/8 1
1/1/81
1/4/8 1
1/4/8 1
1/4/8 1
1/4/8 1
1/5/8 1
1/7/81
1/8/8 1
111 2/81
1/13/8 1
1/14/8 1
1/19/81
1/1 9/81
1/19/8 1
1/21/81
1/21/81
1/21/81
1/2 1/8 1
1/25/81
1/25/81
1/25/8 1
1/25/81
1/25/81
1/25/81
1(25/81
1/25/81
1/25/81
1/26/81
1/27/81
1(27/81
1/26/81
In prep.
In prep.
In prep.
In prep.
3
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80-306 Generic name: Urea/carbamate lacquer
80-307 Polymer of tall oil fatty acids. neopentyl glycol. trimethy!ol
ethane, phthalic anhydride
80-310 Butanenitrile. 2-methyl, 2,2-azobis
80-311 Butanenitrile,2-methyl.2-arnino
80-312 N-lsocyanatotolyl-abietamide
Submitter
Sherwin Williams
Cook Paint
Claimed confiden-
tial business infor-
mation (CBI)
General Printing
and Ink, Inc.
General Printing
and Ink, Inc.
Minnesota Mining
and Minerals (3M)
CBI.
NOVEMBER 1980 PMN STATUS REPORT
FR Citation
45 FR 23509
4/7/80
45 FR 27007
4122/80
45 FR 42012
6/23/80
45 FR 44394
7/1180
45 FR 44394
7/1/80
45 FR 43461
6/27/80
45 FR 46199
7/9/80
45 FR 51264
8/1/80
45 FR 54412
8/15/80
PMN No. Idenity!Generic Name FR Citation Expiration
Date
80-3 13
80-314
80-3 15
Premanufacturers Notices Received During the Month
3-chloro-2-sulfoproplonic acid
2,4-bis [ (4-(N-cyano-N-phenyl sulfonylami no) phenyl)] methyl]
-N-cyano N-phenyl sulfonyl benzeneami ne
4.4’-methylenebls(N-cyanobenzenamine) 2.4-bis [ (4-N-cyano-
amino) phenyl) mettiyl]-N-cyanobenzenami no 4,4-methy-
lenebis [ 2- [ (4-N-cyanoamino)phenyl) methyl]-N-cyanoben-
zenamine
Generic name: dialkyltin-diricinoleate
Generic name: polymer of modified resin esters and mixed
oils
Dimethyl diallyl ammonium chloride-acrylamide-potassium
acrylate terpolymer
Generic name: salt form of acrylic acidacrylate copolymer . -
Vanadic acid, tris (2-methyl propyl)ester
Generic name: polymer of an alkyl acrylate, an alkyl meth-
acrylate. and a saturated cyclic methacnylate
Polymer of epoxidized soybean oil, benzoic acid
Generic name: acrylic resin
Generic name: poly(allyl ether) hydroxy alkyl ester
Generic name: chromophore substituted poly (oxyethylene). -
Generic name: chromophore substituted poly (oxyethlene)...
Generic name: toluene diisocyanate blocked prepolymer . . -.
Generic name: unsaturated melamine formaldehyde meth-
anol resin
Generic name: salt of fatty acid dimer
45 FR 83030
12/1 7/80
45 FR 83023
12/17/80
In prep.
in prep.
45 FR 83018
12/1 7/80
45 FR 82708
12/16/80
45 FR 83021
12/17/80
In prep.
45 FR 82706
12/16l80
45 FR 82706
12/1 6/80
45 FR 82706
12/16/80
45 FR 83020
12/1 7/80
45 FR 83022
12/17/80
In prep.
2/1/80
2/1 /81
2/1/81
In prep.
In prep.
In prep.
In prep.
In prep.
PMN No.
1/27/81
1/27/81
1/28/81
1/28/81
1/28/81
New Chemical Substances that EPA Has Added to the Inventory During the Month
80-33
80-68
80-127
80-129
80-130
80-131
80-139
80-157
Chemical Identification
Vegetable oil fatty acid ester
E-Caprolactone, ethylacrylate, hydroxypropyl-
methylacrylate, styrene acrylic acid polymer
Generic Name: Polymer product of an acrylate
ester and a polyhydroxy compound
Generic Name: Poly(amideester) resin X2-669. . . -
Generic Name: PoIy(amideester) resin X2-600..
2. [ 2- [ 4-(2-hydroxyethoxy) phenyl] ethenyl]-4,6-bi s
(trichloromethyl)-1 ,3.5-triazine
Generic Name: Polymer of Epon 1044. soya fatty
acid. styrene, acrylic acid and di-tertiary butyl
peroxide
Generic Name: Halogenated polyimide
Generic Name: Alkyd resin polymer, fatty acid
and urethane modified
Du Pont
80-175 McCloskey Varnish
Company of the
West
In prep.
In prep.
In prep.
80-316
80-3 17
80-3 18
80-319
80-320
80-32 1
80-322
80-323
80-324
80-325
80-326
80-327
80-328
80-329
2/2/81
2/3/81
2/5/8 1
2/5/81
2/5(81
2/10/81
2/10/81
2/10/81
2/11/81
2/15/81
2/15/81
2/15/81
2/16/81
2/16/81
4
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80-330
80-331
80-332
80-333
80-334
80-335
80-336
80-337
80-338
80-339
80-340
INTERAGENCY TESTING COMM ITTE (IIC)...
SECTION 4(e)
Under Section 4(e), the ITC was established to
recommend to EPA substances which should be
tested for specified effects to determine the haz-
ardous potential of the substances to human health
or the environment. Committee members are: Coun-
cil on Environmental Quality (CEQ), Department of
Commerce (DOC), Environmental Protection Agency
(EPA), National Cancer Institute (NCI), National In-
stitute of Environmental Health Sciences (NIESH),
National Institute for Occupational Safety & Health
Administration (OSHA). The committee may list up
to 50 chemicals or categories and is to consider
revising or adding to if s list every 6 months. The EPA
must respond within one year to each recommenda-
tion by initiating rulemaking under Section 4 or
stating its reasons for not doing so. Both ITC reports
and EPA responses appear in the Federal Register.
On October 24, 1980, the ITC sent to EPA its seventh
priority list of chemicals for consideration in pro-
mulgating 4(e) test rules. The report, which added
two chemicals and two chemical categories and
removed one chemical from the list, was published
on November 25, 1980 (45 FR 78432). The two added
chemicals are benzyl butyl phthalate and butyl
glycotyl butyl phthalate, the two new chemical cate-
gories are alkyltin compounds and fluoroalkenes.
Because EPA had addressed all the ITC’s concerns
about chioromethane, that chemical was removed
from the priority list. With the additions and the dele-
tion the priority list now contains 42 entries.
ENTRY DATE OF
DESIGNATION
1. Acetonitrile April 1979
2. Acrylamide April 1978(b )(d)
3. Alkyl epoxides October 1977(a)
4. Alkyl phthalates October 1977(a)
5. Alkyltin compounds October 1980
6. Aniline and bromo, chloro
and/or nitro anilines April 1979
7. Antimony (metal) April 1979
8. Antimony sulfide April 1979
9. Anitmonytrioxide April 1979
10. Aryl phosphates April 1978(b)
11. Benzidine-based dyes November 1979
12. Benzyl butyl phthalate October 1980
13. Butyl glycolyl butyl phthalate .October 1980
14. Chlorinated benzenes,
mono- and di- October 1977(a), (C)
15. Chlorinated benzenes. tn-.
tetra-. and penta- October 1978/c)
16. Chlorianted naphthalenes. . . .April 1978/b)
17. Chlorinated paratfins Octcber 1977(a)
18. Cresols Octoberl977(a)
19. Cyclohexanone April 1979
20. o-Dianisidine-based dyes .. . . November 1979
21. Dichlorornethane April 1978/b)
22. 1,2-Dichloropropane October 1978
23. Fluoroalkenes October 1980
24. Glycidol and its derivatives. . . October 1978
25. Halogenated alkyl epoxides . . April 1978(b)
26. Hexachloro-1,3-butadiene .. . . October 1977(a)
27. Hexachlorocyclopentadiene. . April 1977
28. Hydroquinone November 1979
29. Isophorone April 1979
30. Mesityl oxide April 1979
31. 4.4-Methylenedianiline April 1979
32. Methyl ethyl ketone April 1979
33. Methyl isobutyl ketone April 1979
34. Nitrobenzene October 1977/a)
35. Phenylenediamines April 1980
36. Polychlorinated terphenyls. . . April 1978(b)
37. Pyridine April 1978(b)
38. Quinone November 1979
39. o-Tolidine-based dyes November 1979
40. Toluene October 1977(a)
41. 1,1,1-Trichloroethane April 1978(b)
42. Xylene October 1977(a)
(a) Responded to by EPA Administrator 43 FR 50134
(b) Responded to by EPA Administrator 44 FR 28095
(c) Responded to by EPA Administrator 45 FR 48524
(d) Responded to by EPA Administrator 45 FR 48510
SIGNIFICANT NEW USE .. SECTION 5(a)(2)
Under 5(a)(2), EPA determines when certain uses of
existing chemical substances are for significant
new uses (SNUR). A determination is made by a rule
promulgated after considering all relevant factors.
The factors include the projected volume of
manufacturing and processing of the substance, the
extent to which the new use changes the type and
form of exposure to humans or the environment, the
extent to which the use of the substance increases
the magnitude and the duration of exposure to
humans or the environment and the anticipated man-
ner and methods of manufacturing, processing,
distributing in commerce and disposal of the
substance. Under Section 5(a)(1)(B), persons must
notify EPA at least 90 days before manufacturing,
process or import a chemical sus lance for a signif i-
cant new use, as determined by EPA.
On November 26, 1980 (45 FR 78970), EPA proposed
that certain uses of N-methanesulfonyl-p-toluene
sulfonamide be designated as significant new uses
(SNUR) of the chemical substance. A PMN for this
In prep.
In prep.
In prep.
In prep.
2118/81
2/19(81
2/22/81
2/22/81
Generic name: amino alcohol
Generic name: fatty acid modified acrylic
Generic name: dimethylol propionic acid. disoyate ester .
Generic name: polymer of substituted alkanediol. alkaned-
ioic acid and alkenedioic acid
Generic name: polymer of substituted alkanedioll, alkaned-
ioic acid and alkenedioic acid
Generic name: polymer of substituted alkanediol, alkaned-
ioic acid and alkenedioic acid
Generic name: 2-antracenesuifonic acid, 1-substituted 9.10-
di hydro-9 .1 0-dioxo-4-substituted
Generic name: acrylamid-methacrylic copolymer
Generic name: salt form of acrylic acid-acrylate copolymer
Generic name: salt form of acrylic acid-acrylate copolymer
Generic name: polymer dioll, monocarboxyilc acid diol,
diamine and diisocyanate
In prep. 2/22/81
In prep. 2/22/81
In prep. 2/22/81
In prep.
In prep.
In prep.
In prep.
2/23/81
2/22/8 1
2/22/81
2/24/81
The TSCA Section 4(e) Priority List
5
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chemical substance was received by EPA on
September 5, 1979. On December 4, 1979 the submit-
ter was free to begin production because EPA had
determined that it was not necessary to regulate for
the use and exposure conditions described in the
PMN, However, EPA remained concerned because
exposure increases of the substance in the future
may present a risk that cannot be evaluated today
because there is a lack of toxicity data about this
substance
In the November 26, 1980 notice, EPA proposes to
define as a SNUR any qualitative use of this
substance other than that described in the
September 5, 1979 PMN, or the manufacture or proc-
ess of more than 1,000 pounds of the substance by
any one person for the use described in the PMN.
“The company gave us no information in its 1979
PMN about the effects of this chemicaLon human
health and the environment,” said Steven D. Jellinek,
EPA’s Assistant Administrator for Pesticides and
Toxic Substances, when the proposed rule was
made public. “As a result, our initial review and lack
of immediate concern about its one proposed use
were predicated on the fact that human exposure to
the chemical would be extremely limited. The low ex-
posure expected was due to the small amount to be
produced and the highly restricted way in which it
was to be used.”
Jellinek said, “The Agency intends to take literally
the production and exposure assumptions provided
by firms submitting premanufacture notices. If the
toxicity of a new substance is either significant or
unknown, EPA will require firms to notify the Agency
in advance of anticipated use changes or production
increases. We will then assess any risks presented
by the new activity to determine whether regulatory
action is necessary to control or prevent changes in
use or production volumes.”
This action marks the second time EPA has initiated
a significant new use rule and is the first such rule
covering a specific chemical. Last August the Agen-
cy proposed a “generic” rule applying to a number of
chemicals. It extended the safeguards of TSCA to
those chemicals normally exempted from the Act--
such as pesticides and drugs, which are regulated
as such under other legislation--when those
substances are processed for new uses that are not
exempt from coverage under TSCA. Additional
significant new use rules will be issued by EPA on
other specific chemical or classes of chemicals, as
conditions warrant.
COURT RULES ON PCBs... SECTION 6(e)
Under Section 6(e), EPA is required to control the
manufacturing, processing, distributing in com-
merce, use, disposal and marketing of
polychiorina ted biphenyls (PCBs). On May 31, 1979,
44 FR (31514) a rule on PCB was promulgated.
On October 30. 1980, the United States Court of Ap-
peals for the District of Columbia Circuit struck
down major portions of the rule on PCBs. The Court
set aside the rule s definition of intact, non-leaking
transformers, capacitors and electromagnets as
totally enclosed uses of PCBs. In addition, the Court
struck down the portion which limited the rule’s ap-
plication to 50 parts per million or more. The Court
issued its opinion in an appellate case brought by
the Environmental Defense Fund against EPA.
REVISED INTERIM POLICY STATEMENT...
SECTION 5
On November 7, 1980 (45 FR 74378) EPA published a
revised interim policy statement for the submission
of PMNs. This clarification was issued as a
response to comments received on PMNs and to
discuss EPA’s experience with PMNs received since
July 1, 1979. Upon publication this clarification
became effective.
On January 10, 1979 (44 FR 2242) EPA proposed
rules arid PMN forms for new chemicals under Sec-
tion 5. At the same time an iterim policy for submis-
sion of PMNs was established. The interim policy
applied to PMNs for substances intended to be
manufactured or imported for a commercial purpose
during the period between July 1, 1979 (30 days after
publication of the TSCA Initial Inventory) and the
publication of the PMN rule. On May 15, 1979 (44 FR
28564), EPA issued a statement clarifying aspects of
the interim policy, modifying it to a limited degree,
and extending the policy to cover all PMNs received
prior to July 1. 1979. The May 15, 1979 statement
replaced the interim policy published on January 10.
1979.
SUBSTANTIAL RISK ... SECTION 8(e)
Under Section 8(e) persons who obtain information
which reasonably supports the conclusion that a
substance presents substantial risk of injury to
human health or the environment must notify EPA
within 15 days. These notices are then reviewed by
OPTS preliminarily and an initial evaluation is
prepared containing, if appropriate, follow-up ques-
tions to the submitter, referrals to other agencies
and decisions to list the chemical for a Section 8
reporting rule or to undertake a formal risk assess-
ment. The submissions and the initial evaluations
are in the Public Reading Room, 447 East Tower,
Waterside Mall, 401 M Street, S.W., Washington,
D.C.
Because of the high volume of telephone requests
for copies of the Section 8(e) notices, which often
are either a one-page letter or an extensive package
of data and articles, the Public Document Room will
no longer be able to take telephone requests for co-
pying. Persons wishing to request a copy of these
notices may write; U.S.E.P.A., Ms. Jerri Green
(A-101), Freedom of Information office, Washington,
D.C. 20460. Requestors will be charged 20 per page
for the duplication of documents. However, there
will be no charge if the total fee in connection with a
request is less than $10.00 (i.e., less than 50 pages).
At page 50 of a request for duplication, a charge of
20t per page is levied for all subsequent pages and
also for the first 49 pages of the request. The
reader’s attention is called to the fact that many 8(e)
notices represent a company’s first review of a
situation or datum and a judgment in compliance
with the statute to submit an notice within 15 days
of obtaining the information. The EPA publishes its
evaluations of these notices in order to make widely
available this Section 8(e) information in an ex-
planatory form that makes it understandable to a
broad public.
6
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Log No 8EHQ-
1080-0365 9/24/80 1,1.1, Trichloro-
etharie
* Final Report on Acute Aspiration
Toxicity
1080-0366 1011/80 Di methyl Hydrogen
Phosphite
* Final Summary Report on Mutagenicity
Battery
1080-0367 10/3/80 Toluene Diamine
Dinitrotoluene
NIOSH Health Hazard Evaluation’
on Employee Reproductive Problems
1080-0368 10/8/80 Organic Compounds
* Sampling and Analysis of Chemicals
in Plant Site and Surrounding Area
Well Water
1080-0370 10/20/80 1,3-butadiene
* Preliminary Inhalation Report on
Chronic Carcinogenicity Study
1180-0371 11/11/80 Varisoft 222 (90°/n)
* Final Report on Sensitivity Study
1180-0372 11/18/80 Dimethlsulfide
borane
* Acute Dermal and Eye Irritation
Study
N-ethyl Perfluor-
oocty I-s u If on-
amido ethanol
N-ethyl Pert luoro-
heptyl sulfon-
amide ethanol
* Preliminary Oral Teratology Study
* Preliminary Oral Teratology Study
1180-0375S 11/21/89 Cadmium Salts of Parateri-
tiary-butyl
* Acute Dermal Toxicity Study
1280-0376 11/26/80 Nitrosamines in
alkyl dimethyl
amine oxides
N-nitrosodi methyla-
mine
Preliminary Report on Product
Contamination
minis tra for to initiate a proceeding for the issuance.
amendment or repeal of a rule under Section 4. 6, or
8, or an order under Section 5(e) or Section 6(b)(2).
[ CAS No.] WithIn 90 days after the filing of Section 21 petition,
EPA must either grant or deny the petit/of. Under
Section 6(a), if EPA finds that there is a reasonable
basis to conclude that a chemical substance will
present an unreasonable risk of injury to health or
the environment it shall apply one or more of several
71-55-6 requirements to the extent necessary to protect ade-
quately against this risk.
On May 5, 1980, Mr. Walter Fitzpatrick. of Stony
Brook. N.Y.. filed a citizen’s petition under Section
868-85-9 21, requesting the EPA initiate a proceeding for the
issuance of a rule under 6(a) to prohibit the manufac-
ture and distribution of nitrilotriacetic acid (NTA). as
a detergent additive. The petition stated that NTA is
25376 45 8 teratogenic, affects various body functions and
25321-14-6 does not slow down or stop eutrophecation in
coastal and estuarine waters. This petition also
asserted that there are safe and economically feasi-
ble alternatives to the use of NTA in detergents.
On November 3, 1980 (45 FR 72773) EPA denied the
petition based on the findings presented in a docu-
ment “Final Report, NTA.” This risk assessment
concluded that the projected levels of general
106-99-0 population exposure from the use of NTA in laundry
detergents would be generally low and that the
associated risks to human health would also be low.
However. if at any time substantial new evidence
suggesting that NTA presents an unreasonable risk
to health or the environment, EPA will reevaluate its
position.
At the time of the petition denial, EPA, in a letter to
Procter & Gamble, urged manufacturers and pro-
cessors of NTA to limit occupational exposure and
to perform additional monitoring and environmental
1691-99-2 studies. EPA also recommended that NTA not be us-
ed in consumer products to which there is direct der-
6855-73-7 mal or oral exposure, such as in shampoos, foods.
and hand washing detergents.
REPORTING RULES
NOTIFICATION OF EXPORT..SECTION 12(b)
Under 12(b), a person in the United States who ex-
ports or intends to export to a foreign country a
chemical substance or mixture for which certain re-
quirements are in effect must notify EPA of such ex-
portation. Upon receipt of such a notice, EPA must
furnish to the government of the country of import, a
notice of the TSCA action taken with respect to that
substance or mixture. The requirements triggering
export notification are: final Section 4 testing rules
or Section 5(b)(4) risk listing for test data; proposed
and final Section 5 and 6 rules; orders issued under
Section 5 and an action pending or relief granted
under Section 5 or 7.
On December 16, 1980, (45 FR 82843), EPA published
a final rule outlining notification procedures that an
exporter must follow in order to comply with Section
12(b). The regulation also outlines what action EPA
will take upon receipt of such a notice. The purpose
of this rule is to alert a foreign government to
hazards that may be associated with certain
SECTION 8(e) NOTICES OF SUBSTANTIAL RISK:
OCTOBER-NOVEMBER 1980
13292-87-0
1180-0373S 11/19/80
1180-0374S 11/19/80 Potassium Salt of 68391-09-3
Perfluoroalkyl Sul-
fonates
16430-20-5
62-75-9
S at the end of Log Number means a santizeci version with
Privacy Act items
NB: All toxicity. carciriogenicity, teratogenicity ann mutagenicity studies in.-
voice animals. Additional tests )e.g.. bacteria cell) are noted or are included in
the term battery.’
CITIZENS’ PETITIONS... SECTION 21
Under Section 21, any person may petition the Ad-
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chemical substances or mixtures being exported to
that country from the customs territory of the United
States.
This 12(b) rule requires exporters to submit a notice
for the first annual shipment of the substance to any
given country. There is no form, but the notice, sub-
mitted by mail to EPA, must include the exporter’s
name and address, the name of the substance or
mixture, the date of export or intended export, the
country of import and the section of TSCA under
which EPA has taken action. Within five working
days, EPA will advise the foreign government of the
impending exportatic-n and the U.S. regulatory ac-
tion taken with respect to the substance or mixture.
Thus, for a Section 12(b) listed sustance or mixture a
company is only obliged to notify once per calendar
year per country/chemical transaction. It should be
understood that whatever limited scope or limited
application of a proposed or final rule, the chemical
becomes suoject to Section 12(b) notification.
Regardless of the scope or purpose of the intended
exportation there is an obligation to notify EPA
under Section 12(b).
The Section 12(b) rule as of January 15, 1981 applies
to the following chemicals by request of the stated
TSCA actions:
F=final rule
P=proposed rule
CHEMICALS
TSCA ACTIONS
PCBs 1
F
CFCs 2
F&P
2,3,7.8 - TCDD 3
F
Asbestos
P
1. Polychlorinated Bipheny)Is; 2. Chlorotluorocarbons: 3. 23.7.8
TetrachIorodibenz o p-dtoxrn
CHEMICAL IMPORTS AND EXPORTS ... SECTION 13
Under Section 13, the U.S. Treasury Department is
required to refuse entry into the United States
customs territory to chemical substances, mixtures
or articles containing chemical substances or mix-
tures that do not comply with TSCA rules, or that are
offered for entry in violation of any TSCA rule or
order under Sections 5, 6, or 7 that are in effect. In
addition, Section 13 requires the Treasury Depart-
ment to consult with EPA and issue rules to ad-
minister this program.
On December 1, 1980, there was published jointly in
the Federal Register, an EPA Section 13 policy state-
ment (45 FR 79730) and a Treasury Department pro-
posed rule on chemical imports (45 FR 79730). In its
notice, the Treasury Department proposes to amend
the U. S. Customs laws to regulate, through a cer-
tification procedure, any chemical substance, im-
ported in bulk or as a part of a mixture that enters
the customs territory of the United States.
Chemicals that are a part of articles are exempt at
this time but the regulations may be modified later
by specific EPA rule to include such chemicals.
Certification will be accomplished by typing a brief
statement on standard entry document or invoices
to the effect that all chemical substances in a ship-
ment comply with all rules under TSCA and none are
offered in violation of TSCA. The importer must sign
this statement.
Because TSCA treats import the same as manufac-
ture, any responsibilities placed on domestic
manufacturers also extend to importers. Thus, an
importer must be aware of whether his chemical im-
port is included in the TSCA inventory or is subject
to Premanufacture Notification (PMN) as a “new”
chemical. Importers should also check to determine
whether their chemical substances fall within
significant new use, as defined by a Section 5 rule,
and are therefore subject to PMN. In addition,
awareness of chemicals subject to specific controls
as hazardous substances under Section 6 is re-
quired to certify compliance. The requirements for
imports will continually change as substances are
added to the Inventory and as new rules are
developed under other sections of TSCA. Conse-
quently, it is important that importers remain inform-
ed of TSCA rules.
Public comment on both proposals are solicited un-
til March 2, 1981. EPA specifically desires com-
ments on ways it can assist the chemical import
community in awareness and compliance. There will
be an opportunity for persons to make presentations
on February 24th and 25, 1981, if signed up through
the lAO.
STUDIES & SUPPORT ACTIVITY
GENERAL ACCOUNTING OFFICE REPORT
The United States General Accounting Office (GAO)
report to Congress, reviewing EPA’s four year ad-
ministration of TSCA, is available through the In-
dustry Assistance Office.
PCB ALERT for FOOD and FEED FACILITIES
A revised edition of “Polychiorinated Biphenyls: An
Alert for Food and Feed Facilities” is available. The
booklet urges people in the food and teed industries
to be continually aware of the serious potential prob-
lems associated with use and disposai of PCB-
containing equipment. The booklet provides inf or-
mation to help set up contamination prevention pro-
grams and provides information on current PCB
reguisitions.
EPA NEW CHEMICAL ACTIVITIES STATUS REPORT
The second edition of EPA’s chemical activity status
report will be available shortly. Reservations are be-
ing accepted for the two-volume set.
The status report, current to July 1980, is a gathering
of information of EPA’s activities relating to
chemical substances but is not limited to chemical
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regulatory activities. Included in the report are ongo-
ing and completed technical assistance informa-
tion, preregulatory assessments, chemical and
biological testing and monitoring programs and
labeling requirements. This edition is the first to in-
clude the chemical activities of EPAs Office of
Research and Development.
The data in this report exists in an interactive data
base and can be reached for either specific
chemicals or specific types of activities. Given a list
of chemicals, this report can be used to quickly
determine who in EPA regulates. is considering
regulating or assessing a chemical and what scien-
tific or technical work has been done on the
substance.
REPORTS ON SECTION 5 PROPOSED RULES
EPA has published a draft analysis of the proposed
rules implementing Section 5 of TSCA. The more
than 70-page report examines the major alternatives
that EPA considered in developing Section 5 rules
and explains the rationale for the Agency’s choice
among the alternatives.
In conjunction with the analysis, EPA has also
printed a contractor’s analysis of the economic im-
pact Section 5 rules will have on the chemical in-
dustry. The contractor’s analysis consists of a basic
report and two appendices.
REPORT ON IMPLEMENTING THE CFC PROPOSED
RULE
An EPA contractor study on the economic implica-
tions of regulating chlorofluorocarbons (CFCs)
emissions is now available. The study focuses atten-
tion on the industries that produce and use CFCs
and assesses the possible effects of regulation on
the industries and their customers. Along with the
study, EPA has published three other contractor pro-
duced documents containing material related to the
study. One report documents a briefing given to EPA
executives and others. It sums up the study’s results
and is recommended to those who seek a concise,
nontechnical summary of the basic study. The sec--
ond document is a more detailed analysis of flexible
foam application. The third gives an extensive
description of the industries that produce the
chemicals used in making CFCs.
SUPPORT DOCUMENTS on ASBESTOS-
CONTAINING MATERIALS IN SCHOOLS
EPA has just published a preliminary statement on
the health effects and the magnitude of exposure to
humans of asbestos-containing friable materials in
schools. The more than 100-page support document
is a draft and has been released for comment on its
technical merit and policy implementation.
Also recently published is an EPA contractor
economic impact analysis of the proposed Section 6
identification and notification rule pertaining to
asbestos-containing friable materials in schools.
SECOND SECTION 8(e) VOLUME PUBLISHED
EPA has just published a second volume of initial
evaluations o substantial risk notices, Section 8(e).
The latest volume covers the July 1, 1979 to January
31, 1980 period. The substantial risk volumes are
issued to enable the public to have access to the in-
formation and to provide examples of submitted in-
formation and EPAs evaluation of it. The informa-
tion should help anyone subject to Section 8(e) to
better understand the types of information that
should be submitted to EPA.
COMPENDIUM ON EPA-STATE AGREEMENTS
EPA has cooperative agreements on environmental
matters with the States and U.S. territories. The
agreements are management tools EPA and the
more local governments can use to focus attention
on environmental activities and problems that need
priority attention. The Office of Pesticides and Toxic
Substances has just published a book containing
synopses of the Agency’s FY 1980 environmental
agreements. The information in the book ‘Perspec-
tives on State-EPA Grant Activities” can help state
and territory managers to know about each others’
activities, encourage program cooperation and lead
to an exchange of environmental information.
JELLINEK REVIEWS PMN HISTORY
EPA has learned two important lessons as a result
of reviewing about 300 PMNs, Steven D. Jellinek. As-
sistant Administrator for Pesticides and Toxic Sub--
stances, told a Japanese audience recently.
“First, that section 5(e) appears to be a very powerful
tool, indeed, and second, that most of the new chem-
icals we’ve seen do not appear to require EPA in-
tervention prior to entering commerce,” Jellinek said
at a Tokyo seminar.
However, new chemicals entering commerce without
objection may later require action if the chemical is
produced in higher volume or used in ways different-
ly that originally proposed by the initial submitter,
Jellinek said. “We will require resubmittal of PMNs
for chemicals that don’t appear to pose an unreason-
able risk as currently projected for use -- such as an
enclosed intermediate, but that may pose such risks
if used differently -- such as solvents in consumer
products.”
More than 30 chemicals are now awaiting signifi-
cant new-use rules under section 5(e)(2), Jellinek
said. EPA has proposed one significant new-use rule
and a second one is planned
EPA’s PMN experience shows that the U.S. chemical
industry generally does not test its new chemicals or
evaluate their risks, Jellinek said. Approximately 25
percent of all notices received so far have had no
health or safety data, not even on physical or
chemical properties. When toxicity data has been in-
cluded, only limited results such as acute tests and
some mutagenicity screens have been given.
“This means that the EPA staff has to develop toxici-
ty profiles on its own by comparing the structurelac-
tivity relationship of the new chemical to similar
substances and by conducting literature searches
on the analogue chemicals,” Jellinik said, “This has
placed an extraordinary burden of EPA’s limited
resources. We believe that industry must begin to
shoulder the burden.”
EPA can use several tools to encourage industry to
generate risk information, Jellinek said.
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EPA will continue to use section 5(e) when safety in-
formation is needed. The Agency will issue testing
guidance and designate certain chemicals for a risk
list under its 5(b)(4) authority. A company submitting
a PMN for a risk list chemical would have to demon--
strate that the substance or its use did not present
an unreasonable risk.
Jellinek said in the future- it is possible that cate-
gories of chemicals might be exempt from PMN re-
quirements by an EPA advance determiniation that
the chemicals did not present unreasonable risks to
health or the environment.
A copy of Mr. Jellinek ‘S October 30, 1980 speech
before the Fuji Techno Systems seminar may be ob-
tained by calling the Industry Assistance Office .
“WHERE WE STAND”
EPA has just updated Where We Stand a popular
and informal accounting of TSCA activities. The
12-page tact sheet highlights what the TSCA man-
date is, and the scope, strategy and priorities of the
administration of the law. The latest PMN and
testing rule activities are explained along with TSCA
action on PCBs, dioxin and asbestos.
TSCA AND THE PRESIDENTS
As of this date, the Toxic Substances Control Act
(TSCA) is slightly more than four years old. As a new
President enters the White House, this may be a
good time to review the role of recent Presidents in
TSCA’s development.
The genesis of TSCA probably was a Council of En-
vironmental Quality (CEQ) report called “Toxic
Substances” offered to President Richard Nixon in
1970. The CEQ itself was new in those days,
established by law in 1969 to formulate and recom-
mend to the President policies promoting and im-
proving the Nation’s environmental quality.
Using the knowledge gained from “Toxic
Substances” and other sources, President Nixon on
February 8, 1971 told Congress: “As we have
become increasingly dependent on many chemicals
and metals we have become acutely aware of the
potential toxicity of the materials entering our en-
vironment. Each year hundreds of new chemicals are
commercially marketed and some of these
chemicals may pose serious potential threats. Many
existing chemicals and metals, such as PCBs
(polychlorinated biphenyls) and mercury, also repre-
sent a hazard.
“It is essential,” the President continued, “that we
take steps to prevent chemical substances from
becoming environmental hazards. Unless we
develop better methods to assure adequate testing
of chemicals, we will be inviting the environmental
crises of the future.”
Mr. Nixon then became the first President of the
United States to propose to Congress a toxic
substances control program.
“I propose that the Administrator of EPA be em-
powered to restrict the use or distribution of any
substance which he finds is a hazard to human
health or the environment.
“I propose that the Administrator be authorized to
stop the sale or use of any substance that violates
the provisions of the legislation and to seek im-
mediate injunctive relief when use or distribution of
a substance presents and imminent hazard to health
or the environment.
“I proposed that the Administrator be authorized to
prescribe minimum standard tests to be performed
on substances.”
Mr. Nixon ended his Congressional message by say-
ing, “the legislation, coupled with the proposal on
pesticides and other existing laws, will provide
greater protection to humans and wildlife from in-
troduction of toxic substances into the environment.
What I propose is not to ban beneficial uses of
chemicals, but rather to control the use of those that
may be harmful.”
Almost immediately, bills on toxic substances were
dropped into the hoppers on both sides of the Hill,
but legislative action on chemicals in 1971 was
limited.
A little over a year later (March 2, 1972) in a special
message to Congress on health care, Mr. Nixon
reminded Congress that the TSCA action he propos-
ed a year earlier “awaits action by Congress.”
The President’s 1972 reminder fell on deaf ears. On
February 15, 1973 in his State of the Union message
on Natural Resources and the Environment, Mr. Nix-
on told the new 93rd Congress, “I was keenly disap-
pointed when the last Congress failed to take action
on many of my legislative requests related to our
natural resources and the environment.”
That spring and summer both the House and Senate
passed TSCA bills. But these bills differed and a
TSCA Congressional solution was not to be found
until three years later during President Gerald Ford’s
administration. Although there were strong dif-
ferences of opinion as to specific features in the pro-
posed law, there was little dispute over the testing
provisions (which eventually become section 4 of
TSCA). What was to become section 5 - how new
chemicals were to be treated - was much discussed.
In Congress, there were three basic approaches to
reviewing new chemicals. Some forces wanted a
premarket clearance system, similiar to the system
used to federally register new drugs and pesticides.
This approach was favored in the Senate and had the
backing of many environmental groups.
A second legislative approach was a premarket
notification clearance system, but limited to
chemicals that EPA had determined would present
an unreasonable risk. Support for this approach was
stronger in the House and favored by industry.
The winning legislative idea of a general
premarketing notification method originally sup-
ported by the Nixon Administration was successful-
ly backed by President Ford. With the Section 5 pro-
vision settled, Congress approved the Act and Presi-
dent Ford signed TSCA into law. In signing the
legislation, President Ford said on October 12, 1976,
“I believe this legislation may be one of the most im-
portant pieces of environmental legislation that has
been enacted by the Congress.
“This toxic substances control legislation provides
broad authority to regulate any of the tens of
thousands of chemicals in commerce. Only a few of
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these chemicals have been tested for their long-term
effects on human health or the environment.
Through the testing and reporting requirements of
the law, our understanding of these chemicals
should be greatly enhanced. If a chemical is found to
present a danger to health or the environment, ap-
propriate regulatory action can be taken before it is
too late to undo the damage.’
President Ford also said the bill closes a gap in our
current array of laws to protect the health of our peo-
ple and the environment. The Clean Air Act and the
Water Pollution Control Act protect the air and water
from toxic contaminants. The Food and Drug Act
and the Safe Drinking Water Act are used to protect
the food we eat and the water we drink against
hazardous contaminants. Other provisions of ex-
isting laws protect the health and the environment
against other polluting contaminants such as
pesticides and radiation. However, none of the ex-
isti ng statutes provide comprehensive protect ion.
“This bill provides broad discretionary authority to
protect the health and environment. It is critical,
however, that the legislation be administered in a
manner so as not to duplicate existing regulatory
and enforcement authorities.’
President Ford concluded by saying, “the ad-
ministration, the majority and minority members of
the Congress, the chemical industry, labor, con-
sumer, environmental, and other groups all have con-
tributed to the bill as it has finally been enacted. It is
a strong bill and will be administered in a way which
focuses on the most critical environment problems
not covered by existing legislation while not over-
burdening either the regulatory agency, the
regulated industry, or the American people.”
The Act became effective on January 1, 1977 just as
Jimmy Carter was moving to Washington. In May
1977, President Carter stressed the need for TSCA’s
preventive approach in his environmental message
to Congress. He said, “The presence of toxic
chemicals in our environment is one of the grimmest
discoveries of the industrial era. Rather than coping
with these hazards after they have escaped into our
environment, our primary objective must be to pre-
vent them from entering the environment at all.”
TSCA enables the Federal Government, for the first
time, President Carter said, “to gather the informa-
tion on chemical substances needed to determine
their potential for damaging human health and the
environment, and to control them where necessary
to protect the public. My FY 1978 budget provides
nearly $29 million - a threefold increase over Fiscal
1977 - for the Environmental Protection Agency to
implement this important Act.”
The law, controlling toxic substances had taken six
years to write. It has now been followed by four years
of administration.
During the latter period, EPA has promulgated TSCA
rules for reporting, storing, retrieving and using
chemical information while protecting confidential
business information. Under TSCA, chemicals are
being assessed and in a few cases controlled by the
Act’s authority. Legal machinery has been establish-
ed under TSCA to review new chemicals as to their
effect on business and the environment before the
substances are manufactured or imported.
To be more specific, under TSCA, an inventory of
chemical substar 1 ces was compiled through a
system of reporting that involved some 7,400
chemical manufacturers. This Initial Inventory,
published on June 1, 1979 contained over 47,000
chemicals. During a second reporting period, pro-
cessors and users of chemicals were given an oppor-
tunity to report. The Revised Inventory made
available on July 30, 1980 brought the total to more
than 55,000 chemicals subject to TSCA.
On July 1, 1979, 30 days after publication of the
Revised Inventory the premanufacturing notification
(PMN) requirements of TSCA became effective. The
PMN provision requires any person who intends to
manufacture a chemical substance subject to TSCA
but not in the Revised Inventory to submit a
premanufacturing notice to EPA at least 90 days
before manufacture or import. During the PMN
review period, EPA must evaluate the health and en-
vironmental effects of the chemical throughout the
entire life cycle from manufacture to disposal.
TSCA also gives EPA the authority to require testing
of chemicals in order to develop data to aid in deter-
mining the risks that such substances may present
to health and the environment. To aid the Agency in
choosing substances the law required the
establishing of a group, the Interagency Testing
Committee (ITC), to recommend substances to EPA
for priority consideration for proposed test rules.
The ITC has now recommended 42 chemicals and
categories of substances.
TSCA also permits EPA to select, on its own, addi-
tional chemicals for testing. EPA has proposed calls
for reporting and recordkeeping on chemical produc-
tion, use, byproduct and exposure on 2.300
chemicals. Here the intention is to let EPA make a
sound preliminary assessment of a chemical of high
exposure potential or one on which toxicity informa-
tion has been previously obtained.
Testing under TSCA begins with an hazard assess-
ment of the physical, chemical and biological pro-
perties of a substance and its potential for injury to
health or the environment. Next, there is an EPA
assessment of risk to humans as to what extent peo-
ple are exposed and under what conditions the ex-
posure occurs.
The TSCA testing standarus are to be directed at
health effects such as oncogenicity, teratogenicity,
mutagenicity and environmental fate, persistence
and ecological effects. All EPA test standards must
be acceptable to other Federal agencies that require
such testing.
These are some of the administrative actions taken
in the last four years to fulfill the requirements of
TSCA.
Now, the process will continue or change with a new
President in the Oval Office. He will be the fourth
President to be directly confronted with one of to-
day’s serious problems - how to control toxic
substances to protect human health and the environ-
ment.
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