Further Analysis of Toxic Substances Control Act

On October 24, Mr. Harry Havens (Director, Office of Program Analysis) testified before the Subcommittee on the Environment. His testimony was based upon our staff paper "A Comparison of Three Estimates of Costs of the Proposed Toxic Substances Control Act" (OPA-76-6). In order to resolve the apparent differences between our testimony and the testimony of the Manufacturing Chemists Association (MCA), you asked us, in your letter of November 7, 1975, to study some of the issues further. Part of our original testimony dealt with the MCA "Study of the Potential Economic Impacts 6f the Proposed Toxic Substances Control Act as Illustrated by Senate Bill S. 776 (February 20, 1975)," and we found that several of the statements in that study were not well documented. In order to see if these- statements could be substantiated by information not included in the MCA study, we met with representatives of the MCA and discussed their background information and our points of disagreement.