GAO 

Unitid Stit.es General Accounting Office 

Report to Congressional’Requesters 

July 1995 TOXIC SUBSTANCES 

EPA Should Focus Its 

ChemicaJ Use ,’ 

.‘, Inventory on 

Suspected Harmful 

: .Substances 

(’ 

‘. 

__“-~ ~. 

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 Barry 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 generaJ 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information on chemical use is often scarce, incomplete, or outdated.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) dete r-mining 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. 

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 

Page 1 GAO/RCED-96-165 EPA’s Chemical Use Inventory 
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 GAWBCED-95165 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 crtn 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,’ 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 Beginning in July 1993, representatives of EPA, the chemical industry, 

Chemicals and Data 

for the Inventory 

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 

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

Page 3 GAO/RCED-95-166 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 pians 

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-SK-L6S 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 

.--.- 

2Toxic Substances Control Act: Prelimim-q Observations on Legislative Changes to Make TSCA More 

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

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

Page 5 GAO/RCED-95-166 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 

tiardous 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 OLU 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 

3The 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. 

4The 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. 

Page6 GAOiRCED-95-165 EPA’s Chemical Use Inventory 
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 quzdity 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 GAWRCED-95-165 EPA’s Chemical Use Inventory 
. . _.. ..- 

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

to Develop Inventory Chemical Use Inventory, including the chemicals and data to be induded 

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/lWED-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.6 

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 

-..--- 

‘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 GAOiRCED-96-166 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, bn 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 
-- .- ~--. 

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 mnnber 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 GAOLRCED-95-165 EPA’s Chemical Use Inventory 
Appendix I I-_~~ ~~_~ __-._ ~.-~ 

%$=-Contributors to This Report 

Resources, 

Cornmunity, and 

Economic 

~.-_~ -.-- 

Lawrence Dyckman, Associate Director 

Edward A. Kratzer, Assistant Director 

J. Kevin Donohue, Adviser 

Vincent P. Price, Evaluator-in-Charge 

Development Frank J. Gross, Senior Evaluator 

Division, Washington, 

D.C. 

(160249) Page 14 GAO/RCED-95-166 EPA’s Chemical Use Inventory 
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