# GAO Unitid Stit.es General Accounting Office 

# ReporttoCongressional’Requesters

July 1995 

# TOXICSUBSTANCES

EPAShouldFocusIts ChemicaJUse,’ .‘, Inventoryon SuspectedHarmful :.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 ofthe chemicals to which millions of consumers and workers aswell asthe generaJ public are potentially exposed. While the amount of exposure to achemical canvary greatly depending on its use,the Environmental Protection Agency’s (EPA) information on chemical use isoften scarce, incomplete, or outdated. To obtain the data it needs to assessthe risks posed by chemicals, EPAis planning to develop aChemical Use Inventory.

Concerned about the adequacy of information on chemical risks, you requested that we review EPA’S efforts to develop this inventory. Onthe basis of discussions with your office, we focused our review on (1) deter-mining the extent to which agreement exists on the chemicals and data to beincluded 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 beincluded in the inventory, the specific types of data that should be obtained, and the sources ofthese 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 12,000chemicals. However, most organizations believe that the inventory should include substantially fewer chemicals than the number EPAhas proposed. Our past work hasshown that EPA does not have the resources to effectively compile and analyze information on alarge number of chemicals. Therefore, the inventory could be more useful to EPAand other interested parties if it initially focused on asmaller number ofthe highest-priority chemicals known to present risks to health and the environment and was expanded asnecessary. Furthermore, while chemical industry members
are concerned about revealing confidential business information that would harm their competitive positions, EPAofficials maintain that the

Page 1 GAO/RCED-96-165 EPA’s Chemical UseInventoryB-261203

._-_ _~--- agency will ensure that legitimate confidential business information is protected in the inventory.

EPAofficials have made no firm decisions about the specific features ofthe inventory or how it will be implemented. EPAofficials met with representatives ofthe chemical industry, public interest groups, and others in April 1995for technical discussions on alternative proposals for implementing the inventory. According to EPAofficials, the agency has not yet decided whether to implement the inventory through the regular federal rulemaking process, which may take 2years 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 aswell asthe extent ofhuman exposure to them. To fully assesshuman exposure to achemical, EPAneeds to know the number of persons exposed, the means of exposure, and the amount and duration ofthe exposure. Actual measurements ofexposure for the thousands of chemicals in use are not practicable because ofthe extensive monitoring equipment and staff resources required. Consequently, EPA estimates the types and amounts of exposure onthe basis ofachemical’s physical properties and use, the industrial processes used to produce and process the chemical, the production volumes, and the types and amount ofthe releases ofthe chemical into the environment.

The Toxic Substances Control Act (TSCA) authorizes EPAto 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 onthose already in the marketplace. Under the act, EPAcan control the production, distribution in commerce, use, and disposal of chemicals. TSCAapplies 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 achemical canvary substantially depending on its use. However, although EPAofficials believe that TSCAprovides the authority to collect some data on chemical useand

Page 2 GAWBCED-95165 EPA’s Chemical Use InventoryB-261203

-. -_ -. exposure, the agency’s current reporting rules do not require the chemical industry to provide this information.

The Chemical Use Inventory that EPAplans to develop is intended to provide the data on chemical use and exposure that the agency needs to

assess risks. EPAenvisions the inventory asadata basethat will enable the agency to screen chemicals to identify those ofhighest concern aswell as those that are potentially safer and crtnbesubstituted for more harmful chemicals in some applications. To implement the inventory, EPAintends to amend the TSCAInventory Update Rule.

The Inventory Update Rule generally requires chemical manufacturers and importers to report to EPAcertain information about the chemicals they produce or import in excess of 10,000pounds per year. According to EPA officials, the rule covers approximately 9,000chemicals produced or imported by about 2,400facilities. The current rule generally requires chemical manufacturers and importers to provide data every 4years on a chemical’s identity, plant sites, and production volume but not on use or exposure. Such chemicals asinorganic substances,’ polymers, microorganisms, and certain naturally occurring substances are excluded from the rule’s reporting requirements. EPAplans to amend the rule in order to gather data on how chemicals are used and to make other changes to reporting requirements.



# NoAgreement onthe Beginning in July 1993,representatives of EPA,the chemical industry, 

# Chemicals andData 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 EPAon key issues such as(1) the chemicals that should be included in the inventory, (2) the types ofdata that should beobtained, and (3) the sources from which data should becollected. 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 ofthe views expressed bythese organizations may be difficult for EPAto reconcile with its own views. Most ofthese organizations believe that the inventory should address alimited number of high-risk chemicals. While EPAagrees 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 InventoryB-261203

available on exposure are insufficient to identify such chemicals. To develop amore comprehensive data base, EPAhasproposed obtaining information onthe approximately 9,000chemicals included under the current Inventory Update Rule plus about 3,000inorganic 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 beused. Members ofthe chemical industry also expressed concern about revealing confidential business information, saying their competitive positions could beharmed asthey provide EPAwith data for the inventory.



## Number of Chemicals to BeIncluded inthe Inventory The Chemical Manufacturers Association, representing companies that account for over 90percent ofthe U.S.bulk chemical production, has expressed concerns about EPA'Sproposal for acomprehensive Chemical Use Inventory. The association believes that aninventory asproposed by EPA, including several thousand chemicals, would beoverly broad, impose
anextraordinary reporting burden onthe industry, and present EPAwith a significant challenge in information management. The association believes that EPAshould narrow the list ofchemicals in the inventory bytaking into account the chemicals’ hazards, production volumes, and potential for exposure.

The Chemical Manufacturers Association isdeveloping amethod for identifying high-risk chemicals to beincluded in the inventory, and it intends to propose this method to EPA.Although this proposal isnot yet completed, EPAand association officials generally agree onthe concept and the data elements that should beused to identify priority chemicals for the inventory but differ onthe screening process to beemployed.

The Consumer Product Safety Commission and public interest organizations also provided EPAwith their views on the chemicals to be included in the inventory. The Commission generally supports EPA'S pians to include the chemicals covered bythe 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. EPAofficials 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 acomprehensive view ofthe chemicals in products and to identify potential concerns about exposure. Public interest groups did not identify

Page4 GAO/RCED-SK-L6S EPA’s Chemical Use Inventory-. ~__.~_.._~ B-261203

-~-, _~-~~ the specific types or numbers ofchemicals to include in the inventory. However, the groups said that the chemicals included should beselected
onthe basis offactors such astheir toxicity and production levels. Such a selection process would limit the number of chemicals in the inventory.

Asnoted, EPAbelieves that the inventory should include the chemicals
now covered bythe Inventory Update Rule, in addition to inorganic substances. Although EPA officials told usthat the agency isconsidering
measures to reduce the number ofchemicals in the inventory, EPA believes that it is important to include arelatively large number of chemicals in order to gather anappropriate amount of data on chemical use and exposure. These data canthen beevaluated to identify the chemicals that pose the greatest risks because oftheir toxicity and potential for human exposure. EPAalso believes that information isneeded on alarge number ofchemicals to ensure that data areavailable for identifying those chemicals that can beused assubstitutes 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 addto the usefulness ofthe data on chemical useand exposure because these chemicals are generally considered to beof less concern than the other chemicals EPAisproposing for-the inventory.

EPA acknowledges that acomprehensive 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 ofthe inventory’s potential effects on its data management burden, the agency is currently assessing the likely impact onthe industry ofthe increased reporting requirements. EPA plans to analyze the inventory’s costs to the agency aspart ofthe rulemaking process. EPA officials told usthat the agency is considering using thresholds ofproduction volume (for example, amounts above acertain production level) and limited hazard screening to reduce the number of chemicals in the inventory, thereby reducing the reporting and data management burdens,
Although EPAindicates that it needs data on alarge number of chemicals,
our past work shows that EPAneeds to establish some means of setting priorities to ensure that risks to health and the environment are addressed in anappropriate and timely manner.2 In this regard, our past work noted that EPA needs to focus the agency’s resources onthose 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).

Page5 GAO/RCED-95-166 EPA’s Chemical Use InventoryB-261203

the basis oftheir toxicity, production volumes, and potential for exposure, present the highest risk to human health and the environment.

Although EPArecognizes the advantages offocusing onthe chemicals of greatest concern, the agency does not believe that it hasthe chemical use and exposure data it needs to setpriorities for the chemicals to be included in the inventory according to their relative risk. However, our past work indicates that, while EPAmay not have complete information to
assesschemicals’ risks, the agency has enough data on chemicals’ toxicity and production volumes from other sources to assessrisk. These sources include EPA'S reviews ofnew and existing chemicals and other sources that the agency usesto identify chemicals of concern and to target priority testing, such asthose included in the Toxic Release Inventory3 andthe TSCAMaster Testing List.4

While EPAofficials acknowledge that the existing data might provide a basis for selecting priority chemicals for the Chemical Use Inventory, they maintain that amore limited inventory focusing only onthe most tiardous chemicals would necessarily exclude those that are less harmful, thus preventing EPAfrom identifying safer substitute chemicals for certain uses. Nevertheless, it is doubtful that EPAcould obtain and analyze the information it needs to identify such substitute chemicals in a timely manner. As OLUpast work indicates, EPAreviews only about 100 chemicals ayear. At this rate, it would take over acentury to review the approximately 12,000chemicals 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 onthe useand exposure ofthis large number of chemicals. Therefore, given the need for EPAto setpriorities and industry’s concerns about reporting burdens, a more moderate approach, atleast initially focused on asmaller number of priority chemicals, could be more manageable for EPAand 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 isto beareliable basis for determining risk, it must include data on achemical’s users and toxicity as

3TheToxic Release Inventory reports onabout 600toxic chemicals released into the environment, transferred from plant sites, and present in waste from U.S. manufacturing facilities.

4TheTSCA Master Testing List includes chemicals that, on the basis of available knowledge, EPA believes to be of concern and hasdesignated for priority review.

Page6 GAOiRCED-95-165 EPA’s Chemical UseInventorywell ason the conditions under which the chemical is used-for example, whether it is isolated in asealed environment or isaccessible 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 areused. Other members ofthe chemical industry, however, favor limiting the reporting requirements to manufacturers and importers. For example, the Chemical Specialties Manufacturers Association, representing specialty chemical producers, told EPAthat including data from processors in the inventory would greatly increase the industry’s reporting burden and EPA'S data handling requirements.

EPAagrees that the inventory should include data that would allow it to characterize risks. For this purpose, EPAis considering amending the rule to require manufacturers and importers to report data onthe number of workers potentially exposed atprocessing and other sites and on the volumes of chemicals used in different categories of industrial and
consumer products. Furthermore, EPAbelieves 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 onworkers’ exposure. However, EPA acknowledges that including such data would increase the industry’s overall reporting requirements and the agency’s data management responsibilities. EPAofficials told usthat the agency currently isnot planning to include data from processors in the inventory. Furthermore, although EPAofficials recognize the value of obtaining data from the industries that arefinal users of the chemicals, they told usthat TSCAdoes not provide the agency with the authority to collect such data.

The Consumer Product Safety Commission also provided EPAwith its views onthe data to beincluded in the inventory. The Commission told EPAthat it needs information on the quantity of chemicals in specific
consumer products or categories of products and data to estimate the amount ofhuman 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, asasolvent or a pigment; the conditions under which consumers may beexposed 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 InventoryB-261203

EPAofficials recognize the value ofobtaining data on specific consumer products or product categories. However, asnoted above, they believe that obtaining these data would bedifficult because the agency lacks the authority under TSCAto collect information from the segments ofthe industry that are the final users of chemicals. In lieu ofthis information, EPAproposes to require manufacturers to identify the industrial and
consumer uses ofthe chemicals they produce. However, EPA acknowledges that the quzdity ofthe data on end usesthat it would receive from manufacturers could be questionable, because these companies may not beaware ofall ofthe final uses oftheir chemicals.
Representatives of anumber ofpublic interest groups also provided their views. Generally, these representatives believe that the inventory should beused to place public pressure onthe chemical industry to reduce its use oftoxic chemicals. Towards this end, they believe that the inventory should provide data from each chemical production and processing facility
onthe (1) chemicals flowing into, used in, and emitted from the facility; (2) chemical end-users and purchasers oftoxic 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, EPAbelieves that the groups’ data needs can best be addressed under the Toxic Release Inventory. EPAis 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 usthat the agency will consider the data needs ofthe public interest groups in its planned revisions tothe Toxic Release Inventory’s reporting requirements. EPAwill 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 ofthe chemical industry are concerned that the information they provide might beused by competitors to harm their business positions. The Chemical Manufacturers Association isconcerned that reporting data on chemical usewould 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.

TSCAprovides that chemical manufacturers, processors, and distributors may designate the data submitted to EPAasconfidential. Information entitled to confidential treatment includes trade secrets and certain commercial orfmancial information. EPA generally must protect information entitled to confidential treatment from public disclosure.

EPAbelieves that the number ofclaims of confidential information made by the industry under TSCAhas been excessive and that many ofthese claims have been inappropriate. Consequently, EPAhas recently initiated a number ofactions 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, EPAofficials believe that these concerns are insupportable and told usthat the agency will fully protect legitimate confidential business information. They also said that EPAwill require reporting ofdata by ranges, in aggregates, or in other ways to avoid claims concerning confidential business information.



# StatusofEPA’sEfforts EPAofficials have made no final decisions about the specific features ofthe 

# to Develop Inventory Chemical Use Inventory, including the chemicals and data to beinduded and how the inventory will beimplemented. These decisions will be made
on the basis offuture discussions with the chemical industry and other interested parties.
Although EPAinitially planned to implement the Chemical UseInventory through aregulatory 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 aproposed amendment to the Inventory Update Rule. This approach is intended to facilitate and expedite the normal rulemaking process, in which EPAfirst proposes arule and then works to resolve differences among the interested parties. This process cantake 2years or more to complete.

EPAofficials met with representatives ofthe chemical industry, public interest groups, and others in April 1995for 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 towork with the interested parties in attempting to identify an approach that will make the inventory most useful tothe agency and others.

EPAofficials told usthat the agency isuncertain whether the restrictions
on new regulations and the cost-benefit analysis requirements that are currently under consideration in the Congress will beenacted and, if they
arepassed, what the exact provisions ofthe final legislation will be.6 Consequently, EPAofficials told usthat 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 EPAofficials are proceeding to further develop technical aspects of new reporting requirements, they have not yet established aspecific schedule for implementing the inventory.



# Conclusions EPAisdeveloping its Chemical Use Inventory to obtain the data on useand exposure the agency needs to assesschemicals’ risks and to setpriorities for its programs for toxic substances. While EPAhas made no firm decisions on the specific features ofthe inventory, the agency has proposed including about 12,000chemicals. EPAofficials maintain that a broad approach will provide the comprehensive information needed to identify those chemicals that pose risks aswell asthose 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 asmaller scale than currently envisioned by EPA, initially covering possibly asmany asseveral thousand ofthe 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 EPAthe opportunity to assessthe data obtained, reconsider the chemicals and type ofdata 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 EPAand other interested organizations need while at the sametime minimizing the data management burden on both the

-..--- ‘Several bills pending in the Congress would impose restrictions on issuing regulations. For example, S.343and H.R. 9would generally require agencies to conduct cost-benefit analyses before issuing regulations. Other bills, including S.219and H.R. 450,would impose amoratorium on many regulatory actions by agencies.

Page 10 GAOiRCED-96-166 EPA’s Chemical Use InventoryB-261203

agency and the chemical industry, we recommend that when the Administrator of EPAimplements the inventory, the agency begin with a limited number ofthose chemicals, perhaps asmany asseveral thousand, that are suspected ofpresenting the greatest risk to human health and the environment. As information isobtained through the inventory, EPA may need to expand the number of chemicals included and/or substitute other chemicals asappropriate.


# Agency Comments Werequested comments on adraft ofthis report from EPA,bn May 25, 1995,we met with the Director ofthe 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 isawell-written description of issues concerning EPA’S proposed Chemical Use Inventory. Nevertheless, EPAdisagreed with our recommendation asstated in the draft report because the agency did not believe that the inventory should be limited to afew hundred ofthe 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
asmany asseveral thousand chemicals rather than the proposed 12,000, this official said that the agency would consider our recommendation,

Aswe discuss in our report, EPA has concerns about limiting the size ofthe 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 alarge 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 EPAofficials maintain that they are considering employing limited hazard screening to reduce the number ofchemicals in the inventory, EPAbelieves that alimited set ofpotential high-risk chemicals cannot beidentified without the data on exposure supplied through the inventory. While we agree that risks may not bescreened with precision
onthe 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 ofwhich chemicals potentially pose the greatest risks. Initial screening ofchemicals onthis basis could result in a more manageable number of chemicals for which data on exposure could beobtained. Successive screenings onthis basis may provide the accuracy

Page 11 GAO/RCED-95-165 EPA’s Chemical UseInventory-- .- ~--. that EPAneeds but on asmaller universe of chemicals, which could be expanded asneeded.

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 ofthe chemicals make informed choices that include consideration of exposures and risks when selecting chemicals for aspecific use.Aswe discuss in our report, EPA

believes that the agency needs such information on alarge number of chemicals. While including arelatively large number of chemicals in the inventory could provide EPA with the data needed to identify arange ofsubstitute chemicals for agiven use,we continue to question the need for, and EPA'S ability to effectively manage and utilize, data on asmany as 12,000chemicals. Data on the useof asmaller number of chemicals, perhaps asmany asseveral thousand, would bemore manageable for both the chemical industry and the agency andwould provide EPAwith data on asufficient number of chemicals to identify use clusters and potential substitutes that aresafer.

EPA believes that the agency’s risk management capacity should not bethe limiting factor in determining the number of chemicals selected for the inventory. Although we agree that EPA’S risk management capacity should not bethe sole determinant ofthe mnnber included, we believe that this capacity should bean important consideration in implementing the inventory. Similarly, EPAshould consider its data management capacity in deciding how many chemicals to initially include in the inventory. Given that EPAhas not yet determined the extent ofthe reporting burden onthe industry orthe data management responsibilities ofthe agency that would result from the inventory, we continue to believe that it would beprudent for EPAto initially include amore limited number ofchemicals in the inventory until the agency hasdetermined the value ofthe information obtained aswell asthe costs to the industry ofproviding the data and to EPAof managing it and making it available to interested parties.

EPAprovided additional technical comments on our draft report. Wehave made changes in our report asappropriate to accommodate these comments.


# Scopeand Methodology To identify the information needed by EPA,we interviewed EPAofficials, including the Director ofthe Economics, Exposure and Technology Division, Office of Pollution Prevention and Toxics. To obtain information

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on EPA'S efforts to develop the inventory, we interviewed the Chief ofthe Chemical Engineering Branch, Economics, Exposure and Technology Division, in EPA'S Office of Pollution Prevention and Toxics.

Wealso reviewed EPA'S internal and public documents on the inventory program. To identify the views ofthe potential users and suppliers ofthe data in the inventory, we reviewed written comments onthe inventory submitted to EPAbythe 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.

Weconducted our review between April 1994and May 1995in accordance with generally accepted government auditing standards.

Asarranged with your office, unless you publicly announce its contents earlier, we plan no further distribution ofthis report until 10days after the date ofthis letter. At that time, we will send copies to the Administrator of EPAand the Director, Office of Management and Budget. Wewill also make copies available to others on request.

Please contact me at (202) 512-6111 if you oryour 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 UseInventoryAppendix I I-_~~ ~~_~ __-._ ~.-~ 

# %$=-Contributors toThis 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.

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