Pre- Manufacture Notification Under the Toxic Substances Control Act

by Council on Wage and Price Stability on March 13, 1981
by Council on Wage and Price Stability

“Attached are comments of the Council on Wage and Price Stability staff on the Environmental Protection Agency’s Regulatory Analysis of premanufacture notification under the Toxic Substances Control Act. The issues raised in this paper deserve your close attention, and I request it be placed in the public record of this proceeding. The chemical industry is one of the United States’ most successful industries in terms of productivity growth, technological innovation, and overall competitiveness in world markets. In ensuring public protection from chemical hazards, we must avoid needlessly sacrificing the long-run viability of this industry through careless or excessive regulation. The potential of the premanufacture notification program to reduce innovation and productivity growth is particularly alarming. These costs do not manifest themselves immediately, and hence may easily be overlooked. But over time, I think this type of cumulative regulatory burden can seriously weaken our economy. I believe that this issue is serious enough to warrant a reexamination of EPA’s strategy for implementing the Toxic Substances Control Act — particularly the emphasis the agency has placed on regulating new chemicals relative to existing chemicals. My staff will continue to be available to help…”

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