United States General Accounting Office

GAO Report to Congressional Requesters

July 1995 TOXIC SUBSTANCES

EPA Should Focus Its

Chemical Use

Inventory on

Suspected Harmful

Substances

GAO/RCED-95-165

GAO United States

General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-261203 

July 7, 1995

The Honorable Joseph I. Lieberman

The Honorable Harry M. Reid

United States Senate

Little is known about the risks of many of the chemicals to which millions

of consumers and workers as well as the general public are potentially

exposed. While the amount of exposure to a chemical can vary greatly

depending on its use, the Environmental Protection Agency’s (EPA)

information on chemical use is often scarce, incomplete, or outdated. To

obtain the data it needs to assess the risks posed by chemicals, EPA is

planning to develop a Chemical Use Inventory.

Concerned about the adequacy of information on chemical risks, you

requested that we review EPA’s efforts to develop this inventory. On the

basis of discussions with your office, we focused our review on

(1) determining the extent to which agreement exists on the chemicals and

data to be included in the inventory and (2) the status of EPA’s efforts to

develop the inventory.

Results in Brief The chemical industry, public interest groups, and other organizations

have conflicting views on key issues relating to the Chemical Use

Inventory that may be difficult for EPA to reconcile with its own views. EPA

and the various organizations and groups differ concerning which and how

many chemicals should be included in the inventory, the specific types of

data that should be obtained, and the sources of these data. Although EPA

has not yet made final plans for implementing the inventory, the agency

has proposed collecting general data on chemical use and exposure from

chemical manufacturers and importers on up to 12,000 chemicals.

However, most organizations believe that the inventory should include

substantially fewer chemicals than the number EPA has proposed. Our past

work has shown that EPA does not have the resources to effectively

compile and analyze information on a large number of chemicals.

Therefore, the inventory could be more useful to EPA and other interested

parties if it initially focused on a smaller number of the highest-priority

chemicals known to present risks to health and the environment and was

expanded as necessary. Furthermore, while chemical industry members

are concerned about revealing confidential business information that

would harm their competitive positions, EPA officials maintain that the

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B-261203 

agency will ensure that legitimate confidential business information is

protected in the inventory.

EPA officials have made no firm decisions about the specific features of the

inventory or how it will be implemented. EPA officials met with

representatives of the chemical industry, public interest groups, and

others in April 1995 for technical discussions on alternative proposals for

implementing the inventory. According to EPA officials, the agency has not

yet decided whether to implement the inventory through the regular

federal rulemaking process, which may take 2 years or more to complete,

or through negotiations with interested parties to facilitate and expedite

the rulemaking.

Background Little is known about the ill effects that many chemicals in commerce

might have on the people exposed to them. Adverse health effects result

from the chemicals’ toxicity as well as the extent of human exposure to

them. To fully assess human exposure to a chemical, EPA needs to know

the number of persons exposed, the means of exposure, and the amount

and duration of the exposure. Actual measurements of exposure for the

thousands of chemicals in use are not practicable because of the extensive

monitoring equipment and staff resources required. Consequently, EPA

estimates the types and amounts of exposure on the basis of a chemical’s

physical properties and use, the industrial processes used to produce and

process the chemical, the production volumes, and the types and amount

of the releases of the chemical into the environment.

The Toxic Substances Control Act (TSCA) authorizes EPA to collect

information about the hazards posed by chemical substances and to take

action to control unreasonable risks by either preventing dangerous

chemicals from entering commerce or placing restrictions on those

already in the marketplace. Under the act, EPA can control the production,

distribution in commerce, use, and disposal of chemicals. TSCA applies to

new and existing chemicals; it does not apply to pesticides, tobacco,

nuclear materials, firearms and ammunition, food, food additives, drugs,

cosmetics, or medical devices.

Information about chemical use is important for estimating potential

exposure because the amount of exposure to a chemical can vary

substantially depending on its use. However, although EPA officials believe

that TSCA provides the authority to collect some data on chemical use and

Page 2 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

exposure, the agency’s current reporting rules do not require the chemical

industry to provide this information.

The Chemical Use Inventory that EPA plans to develop is intended to

provide the data on chemical use and exposure that the agency needs to

assess risks. EPA envisions the inventory as a data base that will enable the

agency to screen chemicals to identify those of highest concern as well as

those that are potentially safer and can be substituted for more harmful

chemicals in some applications. To implement the inventory, EPA intends

to amend the TSCA Inventory Update Rule.

The Inventory Update Rule generally requires chemical manufacturers and

importers to report to EPA certain information about the chemicals they

produce or import in excess of 10,000 pounds per year. According to EPA

officials, the rule covers approximately 9,000 chemicals produced or

imported by about 2,400 facilities. The current rule generally requires

chemical manufacturers and importers to provide data every 4 years on a

chemical’s identity, plant sites, and production volume but not on use or

exposure. Such chemicals as inorganic substances,1

 polymers,

microorganisms, and certain naturally occurring substances are excluded

from the rule’s reporting requirements. EPA plans to amend the rule in

order to gather data on how chemicals are used and to make other

changes to reporting requirements.

No Agreement on the

Chemicals and Data

for the Inventory

Beginning in July 1993, representatives of EPA, the chemical industry,

public interest organizations, and other groups interested in information

on chemical use met to discuss the agency’s proposal for the Chemical Use

Inventory. Following these meetings, these groups provided written

comments to EPA on key issues such as (1) the chemicals that should be

included in the inventory, (2) the types of data that should be obtained,

and (3) the sources from which data should be collected. The most

extensive comments were received from the chemical industry, public

interest groups, and the Consumer Product Safety Commission—the

federal agency responsible for protecting consumers from harmful

products.

Some of the views expressed by these organizations may be difficult for

EPA to reconcile with its own views. Most of these organizations believe

that the inventory should address a limited number of high-risk chemicals.

While EPA agrees with this position, agency officials believe that the data

1

Generally, inorganic substances are those chemicals that do not contain carbon.

Page 3 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

available on exposure are insufficient to identify such chemicals. To

develop a more comprehensive data base, EPA has proposed obtaining

information on the approximately 9,000 chemicals included under the

current Inventory Update Rule plus about 3,000 inorganic chemicals that

are now excluded under the rule. Furthermore, the various organizations

differ among themselves concerning which chemicals and data should be

included in the inventory and which information sources should be used.

Members of the chemical industry also expressed concern about revealing

confidential business information, saying their competitive positions could

be harmed as they provide EPA with data for the inventory.

Number of Chemicals to

Be Included in the

Inventory

The Chemical Manufacturers Association, representing companies that

account for over 90 percent of the U.S. bulk chemical production, has

expressed concerns about EPA’s proposal for a comprehensive Chemical

Use Inventory. The association believes that an inventory as proposed by

EPA, including several thousand chemicals, would be overly broad, impose

an extraordinary reporting burden on the industry, and present EPA with a

significant challenge in information management. The association believes

that EPA should narrow the list of chemicals in the inventory by taking into

account the chemicals’ hazards, production volumes, and potential for

exposure.

The Chemical Manufacturers Association is developing a method for

identifying high-risk chemicals to be included in the inventory, and it

intends to propose this method to EPA. Although this proposal is not yet

completed, EPA and association officials generally agree on the concept

and the data elements that should be used to identify priority chemicals

for the inventory but differ on the screening process to be employed.

The Consumer Product Safety Commission and public interest

organizations also provided EPA with their views on the chemicals to be

included in the inventory. The Commission generally supports EPA’s plans

to include the chemicals covered by the Inventory Update Rule, in addition

to inorganic substances. However, the Commission believes that EPA

should also include polymers, naturally occurring substances, and the

chemicals produced by microorganisms, which are currently exempt from

reporting under the rule. EPA officials were unable to estimate how many

chemicals are included in these three categories. The Commission believes

that data are needed on how these types of chemicals are used in order to

provide a comprehensive view of the chemicals in products and to identify

potential concerns about exposure. Public interest groups did not identify

Page 4 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

the specific types or numbers of chemicals to include in the inventory.

However, the groups said that the chemicals included should be selected

on the basis of factors such as their toxicity and production levels. Such a

selection process would limit the number of chemicals in the inventory.

As noted, EPA believes that the inventory should include the chemicals

now covered by the Inventory Update Rule, in addition to inorganic

substances. Although EPA officials told us that the agency is considering

measures to reduce the number of chemicals in the inventory, EPA believes

that it is important to include a relatively large number of chemicals in

order to gather an appropriate amount of data on chemical use and

exposure. These data can then be evaluated to identify the chemicals that

pose the greatest risks because of their toxicity and potential for human

exposure. EPA also believes that information is needed on a large number

of chemicals to ensure that data are available for identifying those

chemicals that can be used as substitutes in processes in which more

hazardous substances are now used. However, EPA believes that including

polymers, naturally occurring substances, and the chemicals produced by

microorganisms in the inventory would not add to the usefulness of the

data on chemical use and exposure because these chemicals are generally

considered to be of less concern than the other chemicals EPA is proposing

for the inventory.

EPA acknowledges that a comprehensive inventory will add to the chemical

industry’s reporting requirements and the agency’s data management

responsibilities. Although EPA has not yet determined the extent of the

inventory’s potential effects on its data management burden, the agency is

currently assessing the likely impact on the industry of the increased

reporting requirements. EPA plans to analyze the inventory’s costs to the

agency as part of the rulemaking process. EPA officials told us that the

agency is considering using thresholds of production volume (for example,

amounts above a certain production level) and limited hazard screening to

reduce the number of chemicals in the inventory, thereby reducing the

reporting and data management burdens.

Although EPA indicates that it needs data on a large number of chemicals,

our past work shows that EPA needs to establish some means of setting

priorities to ensure that risks to health and the environment are addressed

in an appropriate and timely manner.2

 In this regard, our past work noted

that EPA needs to focus the agency’s resources on those chemicals that, on

2

Toxic Substances Control Act: Preliminary Observations on Legislative Changes to Make TSCA More

Effective (GAO/T-RCED-94-263, July 13, 1994) and Toxic Substances Control Act: Legislative Changes

Could Make the Act More Effective (GAO/RCED-94-103, Sept. 26, 1994).

Page 5 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

the basis of their toxicity, production volumes, and potential for exposure,

present the highest risk to human health and the environment.

Although EPA recognizes the advantages of focusing on the chemicals of

greatest concern, the agency does not believe that it has the chemical use

and exposure data it needs to set priorities for the chemicals to be

included in the inventory according to their relative risk. However, our

past work indicates that, while EPA may not have complete information to

assess chemicals’ risks, the agency has enough data on chemicals’ toxicity

and production volumes from other sources to assess risk. These sources

include EPA’s reviews of new and existing chemicals and other sources that

the agency uses to identify chemicals of concern and to target priority

testing, such as those included in the Toxic Release Inventory3

 and the

TSCA Master Testing List.4

While EPA officials acknowledge that the existing data might provide a

basis for selecting priority chemicals for the Chemical Use Inventory, they

maintain that a more limited inventory focusing only on the most

hazardous chemicals would necessarily exclude those that are less

harmful, thus preventing EPA from identifying safer substitute chemicals

for certain uses. Nevertheless, it is doubtful that EPA could obtain and

analyze the information it needs to identify such substitute chemicals in a

timely manner. As our past work indicates, EPA reviews only about 100

chemicals a year. At this rate, it would take over a century to review the

approximately 12,000 chemicals the agency has proposed for the Chemical

Use Inventory. Given EPA’s limited capability to review chemicals, it is

unlikely that the agency could effectively utilize data on the use and

exposure of this large number of chemicals. Therefore, given the need for

EPA to set priorities and industry’s concerns about reporting burdens, a

more moderate approach, at least initially focused on a smaller number of

priority chemicals, could be more manageable for EPA and the industry and

more valuable for the agency and other interested parties.

Data Types and Sources The views of chemical industry representatives on the type and sources of

data needed for the inventory vary. The Chemical Manufacturers

Association believes that if the inventory is to be a reliable basis for

determining risk, it must include data on a chemical’s users and toxicity as

3

The Toxic Release Inventory reports on about 600 toxic chemicals released into the environment,

transferred from plant sites, and present in waste from U.S. manufacturing facilities.

4

The TSCA Master Testing List includes chemicals that, on the basis of available knowledge, EPA

believes to be of concern and has designated for priority review.

Page 6 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

well as on the conditions under which the chemical is used—for example,

whether it is isolated in a sealed environment or is accessible for human

exposure.

Although the Inventory Update Rule currently requires reporting only by

chemical manufacturers and importers, the Chemical Manufacturers

Association believes that chemical processors can also provide the

inventory with detailed data on how chemical products are used. Other

members of the chemical industry, however, favor limiting the reporting

requirements to manufacturers and importers. For example, the Chemical

Specialties Manufacturers Association, representing specialty chemical

producers, told EPA that including data from processors in the inventory

would greatly increase the industry’s reporting burden and EPA’s data

handling requirements.

EPA agrees that the inventory should include data that would allow it to

characterize risks. For this purpose, EPA is considering amending the rule

to require manufacturers and importers to report data on the number of

workers potentially exposed at processing and other sites and on the

volumes of chemicals used in different categories of industrial and

consumer products. Furthermore, EPA believes that including data from

chemical processors might make the inventory more comprehensive and

accurate by identifying more facilities that handle toxic chemicals and by

providing additional information on workers’ exposure. However, EPA

acknowledges that including such data would increase the industry’s

overall reporting requirements and the agency’s data management

responsibilities. EPA officials told us that the agency currently is not

planning to include data from processors in the inventory. Furthermore,

although EPA officials recognize the value of obtaining data from the

industries that are final users of the chemicals, they told us that TSCA does

not provide the agency with the authority to collect such data.

The Consumer Product Safety Commission also provided EPA with its

views on the data to be included in the inventory. The Commission told

EPA that it needs information on the quantity of chemicals in specific

consumer products or categories of products and data to estimate the

amount of human exposure to the chemicals in these products. The

information that the Commission needs to estimate exposure includes a

chemical’s function in the product—for example, as a solvent or a

pigment; the conditions under which consumers may be exposed to the

chemical in the product; and the chemical’s vapor pressure or evaporation

rate.

Page 7 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

EPA officials recognize the value of obtaining data on specific consumer

products or product categories. However, as noted above, they believe

that obtaining these data would be difficult because the agency lacks the

authority under TSCA to collect information from the segments of the

industry that are the final users of chemicals. In lieu of this information,

EPA proposes to require manufacturers to identify the industrial and

consumer uses of the chemicals they produce. However, EPA

acknowledges that the quality of the data on end uses that it would receive

from manufacturers could be questionable, because these companies may

not be aware of all of the final uses of their chemicals.

Representatives of a number of public interest groups also provided their

views. Generally, these representatives believe that the inventory should

be used to place public pressure on the chemical industry to reduce its use

of toxic chemicals. Towards this end, they believe that the inventory

should provide data from each chemical production and processing facility

on the (1) chemicals flowing into, used in, and emitted from the facility;

(2) chemical end-users and purchasers of toxic chemicals; (3) number of

workers and consumers handling products; and (4) chemical processors

and processes.

Because these groups’ concerns focus on individual chemical facilities and

their chemical flows, EPA believes that the groups’ data needs can best be

addressed under the Toxic Release Inventory. EPA is considering revising

the reporting requirements for the Toxic Release Inventory in order to

obtain site-specific data on industrial facilities’ chemical flows. EPA

officials told us that the agency will consider the data needs of the public

interest groups in its planned revisions to the Toxic Release Inventory’s

reporting requirements. EPA will not initiate the proposed revisions to this

inventory until it completes ongoing efforts to expand the number of

chemicals and reporting facilities included in this inventory. EPA expects

this effort to take several years.

Industry Is Concerned

About Confidentiality of

Data

Although EPA, the Consumer Product Safety Commission, and public

interest groups believe that the data in the inventory should be made

public, members of the chemical industry are concerned that the

information they provide might be used by competitors to harm their

business positions. The Chemical Manufacturers Association is concerned

that reporting data on chemical use would damage companies’ competitive

positions by disclosing key information about the ingredients of chemical

Page 8 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

products, plans for new products, chemical processes, or improvements to

processes.

TSCA provides that chemical manufacturers, processors, and distributors

may designate the data submitted to EPA as confidential. Information

entitled to confidential treatment includes trade secrets and certain

commercial or financial information. EPA generally must protect

information entitled to confidential treatment from public disclosure.

EPA believes that the number of claims of confidential information made by

the industry under TSCA has been excessive and that many of these claims

have been inappropriate. Consequently, EPA has recently initiated a

number of actions to reduce the number of claims, including proposing

regulatory changes to require companies to substantiate their claims.

Despite industry’s concerns over the public availability of data in the

inventory, EPA officials believe that these concerns are insupportable and

told us that the agency will fully protect legitimate confidential business

information. They also said that EPA will require reporting of data by

ranges, in aggregates, or in other ways to avoid claims concerning

confidential business information.

Status of EPA’s Efforts

to Develop Inventory

EPA officials have made no final decisions about the specific features of the

Chemical Use Inventory, including the chemicals and data to be included

and how the inventory will be implemented. These decisions will be made

on the basis of future discussions with the chemical industry and other

interested parties.

Although EPA initially planned to implement the Chemical Use Inventory

through a regulatory negotiation process, the agency is reconsidering this

approach because some parties are reluctant to participate in the process.

In this process, the agency would work to resolve differences among

chemical industry members, public interest groups, and others before

introducing a proposed amendment to the Inventory Update Rule. This

approach is intended to facilitate and expedite the normal rulemaking

process, in which EPA first proposes a rule and then works to resolve

differences among the interested parties. This process can take 2 years or

more to complete.

EPA officials met with representatives of the chemical industry, public

interest groups, and others in April 1995 for technical discussions on

alternative proposals for implementing the inventory. According to EPA

Page 9 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

officials, they will continue to work with the interested parties in

attempting to identify an approach that will make the inventory most

useful to the agency and others.

EPA officials told us that the agency is uncertain whether the restrictions

on new regulations and the cost-benefit analysis requirements that are

currently under consideration in the Congress will be enacted and, if they

are passed, what the exact provisions of the final legislation will be.5

Consequently, EPA officials told us that they do not know the effect that

these proposed legislative changes may have on the agency’s plans to

revise the Inventory Update Rule. Although EPA officials are proceeding to

further develop technical aspects of new reporting requirements, they

have not yet established a specific schedule for implementing the

inventory.

Conclusions EPA is developing its Chemical Use Inventory to obtain the data on use and

exposure the agency needs to assess chemicals’ risks and to set priorities

for its programs for toxic substances. While EPA has made no firm

decisions on the specific features of the inventory, the agency has

proposed including about 12,000 chemicals. EPA officials maintain that a

broad approach will provide the comprehensive information needed to

identify those chemicals that pose risks as well as those that can substitute

for such chemicals. However, the chemical industry, public interest

groups, and the Consumer Product Safety Commission generally believe

that the number of chemicals in the inventory should be limited. In our

opinion, implementing the inventory on a smaller scale than currently

envisioned by EPA, initially covering possibly as many as several thousand

of the chemicals suspected to present the greatest risk, would provide key

data on chemical use and exposure while limiting the reporting burden on

the chemical industry and EPA’s data management requirements. This

approach would also give EPA the opportunity to assess the data obtained,

reconsider the chemicals and type of data included in the inventory, and

make any necessary adjustments to its approach.

Recommendation To ensure that the Chemical Use Inventory provides the data on chemical

use and exposure that EPA and other interested organizations need while at

the same time minimizing the data management burden on both the

5

Several bills pending in the Congress would impose restrictions on issuing regulations. For example,

S. 343 and H.R. 9 would generally require agencies to conduct cost-benefit analyses before issuing

regulations. Other bills, including S. 219 and H.R. 450, would impose a moratorium on many regulatory

actions by agencies.

Page 10 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

agency and the chemical industry, we recommend that when the

Administrator of EPA implements the inventory, the agency begin with a

limited number of those chemicals, perhaps as many as several thousand,

that are suspected of presenting the greatest risk to human health and the

environment. As information is obtained through the inventory, EPA may

need to expand the number of chemicals included and/or substitute other

chemicals as appropriate.

Agency Comments We requested comments on a draft of this report from EPA. On May 25,

1995, we met with the Director of the Economics, Exposure and

Technology Division in EPA’s Office of Pollution Prevention and Toxics to

obtain the agency’s oral comments on the draft report. During our

meeting, this official stated that overall, the report is a well-written

description of issues concerning EPA’s proposed Chemical Use Inventory.

Nevertheless, EPA disagreed with our recommendation as stated in the

draft report because the agency did not believe that the inventory should

be limited to a few hundred of the most toxic chemicals with the highest

production volumes. However, after we discussed the recommendation

and clarified that we believe that EPA should initially limit its inventory to

as many as several thousand chemicals rather than the proposed 12,000,

this official said that the agency would consider our recommendation.

As we discuss in our report, EPA has concerns about limiting the size of the

inventory because the agency (1) believes it is difficult to screen

high-priority chemicals for the inventory without data on exposure and

(2) wants information on a large number of chemicals used in similar

applications, or “use clusters,” in order to identify safer substitutes. In

addition, EPA believes that the agency’s risk management capacity should

not determine the number of chemicals included in the inventory.

Although EPA officials maintain that they are considering employing

limited hazard screening to reduce the number of chemicals in the

inventory, EPA believes that a limited set of potential high-risk chemicals

cannot be identified without the data on exposure supplied through the

inventory. While we agree that risks may not be screened with precision

on the basis of data on production volumes only, we believe that this type

of information, in conjunction with data on toxicity and other available

data, can provide an indication of which chemicals potentially pose the

greatest risks. Initial screening of chemicals on this basis could result in a

more manageable number of chemicals for which data on exposure could

be obtained. Successive screenings on this basis may provide the accuracy

Page 11 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

that EPA needs but on a smaller universe of chemicals, which could be

expanded as needed.

EPA also believes that data on chemical use and exposure are essential to

identifying groups of chemicals used in similar applications, or use

clusters. EPA believes that this approach is key to helping the users of the

chemicals make informed choices that include consideration of exposures

and risks when selecting chemicals for a specific use. As we discuss in our

report, EPA believes that the agency needs such information on a large

number of chemicals. While including a relatively large number of

chemicals in the inventory could provide EPA with the data needed to

identify a range of substitute chemicals for a given use, we continue to

question the need for, and EPA’s ability to effectively manage and utilize,

data on as many as 12,000 chemicals. Data on the use of a smaller number

of chemicals, perhaps as many as several thousand, would be more

manageable for both the chemical industry and the agency and would

provide EPA with data on a sufficient number of chemicals to identify use

clusters and potential substitutes that are safer.

EPA believes that the agency’s risk management capacity should not be the

limiting factor in determining the number of chemicals selected for the

inventory. Although we agree that EPA’s risk management capacity should

not be the sole determinant of the number included, we believe that this

capacity should be an important consideration in implementing the

inventory. Similarly, EPA should consider its data management capacity in

deciding how many chemicals to initially include in the inventory. Given

that EPA has not yet determined the extent of the reporting burden on the

industry or the data management responsibilities of the agency that would

result from the inventory, we continue to believe that it would be prudent

for EPA to initially include a more limited number of chemicals in the

inventory until the agency has determined the value of the information

obtained as well as the costs to the industry of providing the data and to

EPA of managing it and making it available to interested parties.

EPA provided additional technical comments on our draft report. We have

made changes in our report as appropriate to accommodate these

comments.

Scope and

Methodology

To identify the information needed by EPA, we interviewed EPA officials,

including the Director of the Economics, Exposure and Technology

Division, Office of Pollution Prevention and Toxics. To obtain information

Page 12 GAO/RCED-95-165 EPA’s Chemical Use Inventory
B-261203 

on EPA’s efforts to develop the inventory, we interviewed the Chief of the

Chemical Engineering Branch, Economics, Exposure and Technology

Division, in EPA’s Office of Pollution Prevention and Toxics.

We also reviewed EPA’s internal and public documents on the inventory

program. To identify the views of the potential users and suppliers of the

data in the inventory, we reviewed written comments on the inventory

submitted to EPA by the Consumer Product Safety Commission; various

public interest, environmental, environmental justice, and labor groups;

the Chemical Manufacturers Association; the Chemical Specialties

Manufacturers Association; other chemical industry representatives; and

some individual chemical manufacturing and processing companies.

We conducted our review between April 1994 and May 1995 in accordance

with generally accepted government auditing standards.

As arranged with your office, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 10 days after the

date of this letter. At that time, we will send copies to the Administrator of

EPA and the Director, Office of Management and Budget. We will also make

copies available to others on request.

Please contact me at (202) 512-6111 if you or your staff have any questions.

Major contributors to this report are listed in appendix I.

Peter F. Guerrero

Director, Environmental

 Protection Issues

Page 13 GAO/RCED-95-165 EPA’s Chemical Use Inventory
Appendix I 

Major Contributors to This Report

Resources,

Community, and

Economic

Development

Division, Washington,

D.C.

Lawrence Dyckman, Associate Director

Edward A. Kratzer, Assistant Director

J. Kevin Donohue, Adviser

Vincent P. Price, Evaluator-in-Charge

Frank J. Gross, Senior Evaluator

(160249) Page 14 GAO/RCED-95-165 EPA’s Chemical Use Inventory
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