Table Of ContentGuidebook:
Toxic Substances
Control Act
Volume II
Editor
George Dominguez
President
Springboro Regulatory Services, Inc.
Enfield, Connecticut
Boca Raton London New York
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ACKNOWLEDGMENTS
In reviewing the enormous effort that went into the creation of this Guidebook, I can only once again
complement those on my Editorial Board and our contributors without whose continuous aid and cooperation
this book would not have been possible. In appreciation of their efforts, I would like to repeat the thanks
given to them and to our CRC Press colleagues in the “Acknowledgments” made in what is now Volume
I of this Guidebook.
As Editor, my task was more than eased by the expertise and resourcefulness of my Advisory Board.
My personal thanks goes to each and every one of them for their invaluable assistance in reviewing and
commenting on this publication from its conceptual inception to final publication. Obviously, this board,
regardless of skill or knowledge, could accomplish little or nothing were it not for the actual articles that
represent the substance of the guidebook. I know that I speak for the entire board when I express my
thanks, which is hardly sufficient for the actual work involved, to each of our authors who not only took
the time from their busy schedules to prepare their manuscripts but, more importantly, were willing to
share their knowledge with us in the preparation of this publication. And last, but not least, we must
express our gratitude to the publisher and its internal Editorial Staff, especially Benita Budd, Senior Editor,
CRC Uniscience, who certainly eased the Editor’s burden by doing all of the hard work and leaving him
the glory. May she and the others at CRC Press know that their hard work does not go unnoticed or
unappreciated.
George S. Dominguez
Editor
Wilton, Connecticut
1981
EDITOR
George S. Dominguez, is President of Springborn Regulatory Services, Inc., Enfield,
Connecticut.
Mr. Dominguez received his B.S. and M.B.A. from Kentucky Christian University, Ashland. He is
also a graduate of the Manhattan Medical and Dental Assistant School and the U.S. Army Intelligence
School.
Mr. Dominguez is a member of the Board of Governors of the Synthetic Organic Chemical Manufacturers
Association. He is a member of the Government Relations Committee and Chairman of the Chemical
Regulations Advisory Committee of the Manufacturing Chemists Association. He is also a member of the
Ecology Steering Committee and Chairman of the Toxic Substances Task Force of the National Association
of Manufacturers.
Mr. Dominguez has had numerous publications and is the author of Product Management; Marketing
in a Shortage Economy; How to be a Successful Product Manager; and Business, Government, and the
Public Interest and Government Relations.
Mr. Dominguez was formerly Director, Government Regulations, Safety, Health, and Ecology Depart-
ment, CIBA-GEIGY Corporation, Ardsley, New York. He has also taught and lectured widely, was a
member of the faculty of New York University, Alamance Technical Institute, and has been a frequent
guest lecturer at the New York University Graduate School of Education.
ADVISORY BOARD
Dr. John D. Behun Dr. Robert Polack, Esq.
Manager of Toxic Substances Control Vice President
Mobil Chemical Company Reilly Tar and Chemical Corporation
Edison, New Jersey Indianapolis, Indiana
Dr. Fred D. Hoerger
Manager, Regulatory and Legislative Issues Sarah Shapley
Health and Environmental Research Office of Toxic Substances
Dow Chemical Company U.S. Environmental Protection Agency
Midland, Michigan Washington, D.C.
CONTRIBUTORS
George S. Dominguez Breck Milroy
President Staff Advisor
Springbom Regulatory Services, Inc. International Chemical Affairs Staff
Enfield, Connecticut Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency
Irving L. Fuller, Jr. Washington, D.C.
Director, International Chemical Affairs
Robert Polack, Esq.
Office of Pesticides and Toxic Substances
Vice President
U.S. Environmental Protection Agency
Reilly Tar and Chemical Corporation
Washington, D.C.
Indianapolis, Indiana
Charles Ganz, Ph.D. Leon Starr, Ph.D.
President Director
EN-CAS Analytical Laboratories Environmental, Health, and Safety Affairs
Winston-Salem, North Carolina Celanese Corporation
New York, New York
Richard deC. Hinds, Esq.
Robert M. Sussman, Esq.
Partner
Partner
Cle&ry, Gottlieb, Steen, & Hamilton
Covington & Burling
Washington, D.C.
Washington, D.C.
Peter Barton Hutt, Esq. Carl W. Umland
Partner Environmental Health Coordinator
Covington & Burling Exxon Chemical Americas
Washington, D.C. Houston, Texas
TABLE OF CONTENTS
Chapter 1
Introduction............................................................................................................................................................ 1
George Dominguez
Chapter 2
Judicial Construction of the Toxic Substances Control Act..........................................................................11
Richard deC. Hinds
Chapter 3
Economic Impacts of the Toxic Substances Control Act (Public Law 94-469)......................................... 17
Leon Starr
Chapter 4
The Impact of the TSCA Interagency Testing Committee............................................................................41
Carl W. Umland and Robert Polack
Chapter 5
Premanufacture Notification.................................................................................................................................65
Robert M. Sussman and Peter Barton Hutt
Chapter 6
Substantial Risk Reporting — Industrial Requirements.................................................................................143
George Dominguez
Chapter 7
Confidentiality.......................................................................................................................................................155
George Dominguez
Chapter 8
Environmental Effects Testing...........................................................................................................................169
Charles R. Ganz
Chapter 9
International Aspects of Toxic Substances Control........................................................................................197
Irving L. Fuller and Breck Milroy
Index 212
Volume II 1
Chapter 1
INTRODUCTION
George Dominguez
TABLE OF CONTENTS
I. General.........................................................................................................................................................2
II. Scope and Coverage...................................................................................................................................2
III. Major Regulatory Developments..............................................................................................................3
IV. Health and Environmental Effects Testing.............................................................................................3
V. Use and Objectives of the “Guidebook” ...............................................................................................3
VI. What the Future Holds in Store................................................................................................................4
