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Foreword
in each manufacturing process and determine how much is released to each of the
environmental media. Use accounts not only for potential release to the environment
but also for potential worker exposure and the release into homes and offices in the
products that are sold.
I once attended a meeting at which the USEPA Office of Water was looking for
ideas on how to simplify and make regulations more effective. I suggested the Soviet
system of charging for the toxic impact of chemical releases to the environment.
The response was that it was an interesting idea but would not fit into our admittedly flawed regulatory structure, which was based on the separate regulation of each
medium and firmly entrenched in the agency.
Why can other countries learn from our successes and failures, but we cannot?
Reducing or eliminating the impacts of toxic chemical use requires a new approach.
I started writing this foreword while traveling from Brazil to my home near
Washington, D.C., and was thinking about the lessons learned from reviewing various
global existing programs, how we applied these lessons to propose a toxic chemical
use reduction program for CETESB, and how these same concepts could be applied
to the United States. This book lays out an analysis of the toxic impacts of chemical
releases in the United States based on current TRI data and proposes an approach
to ending our addiction to these chemicals. The approach is built on a review of
previous and current global programs and takes the best components from each to
develop a market-based approach to reducing our use. This market-based approach
would move the downstream costs of toxic chemicals to the point of initial use. This
program builds on the successful TRI program and focuses reduction efforts at the
point of initial use and on the chemicals that have the greatest impact on toxicity.
The impetus and intention behind proposing the program in this book is to spur
thinking among other professionals, especially federal-level policy makers, regarding the next level of toxic chemical use reduction, with the ultimate goal of instituting
policy updates that build on and continue the success of the TRI and other associated
programs. Regardless of how successful past programs have been, to continue progress in any field, especially those concerning public health, it is the responsibility
of professionals like us to reflect on what has worked and what needs to be changed
based on the world as it has evolved. Our proposal is certainly not set in stone; in
fact, we welcome healthy discussion and suggestions on our specific proposed program elements and what modifications, if any, would maximize the effectiveness of
the next level U.S.-based toxic chemical usage reduction program. Due to the fact
that this is an initial proposal to generate a new way of thinking and move toward
certain toxic chemical use reduction policy adjustments, we also recognize that if
select or even all program elements proposed in this book are deemed appropriate,
additional refinement of details will be required as part of actual program implementation to convert these ideas on paper into actual policy. Some thoughts regarding the
additional conceptual-level steps that could be taken toward this objective to further
refine our initial thoughts over time as part of a formal program, as warranted, are
also provided in this book.
In addition, the analysis of the specific toxicity of any given chemical typically
requires a detailed analysis of exposure pathways and individuals affected. For
the purposes of a toxic chemical usage reduction program, we have simplified the
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