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Oral history interview of the toxic substances control act from the perspective of Mark A. Greenwood

  • 2010-Feb-26

Mark Greenwood, as an undergraduate, wanted to work in government. As a law student, he discovered the emerging field of environmental law. After graduating, he joined the EPA’s Office of General Counsel and eventually became the Assistant General Counsel for Pesticides and Toxic Substances. From there Greenwood joined the newly re-named Office of Pollution Prevention and Toxic Substances as Office Director. His first challenge was recuperating from the failed asbestos rule, a demoralizing event that also effectively eliminated rule-based risk management. At the same time, he was given new tools with the Pollution Prevention Act. The office experimented with voluntary data collection and risk management initiatives, about which Greenwood drew some conclusions during the interview. From his perspective, the Toxic Substances Control Act (TSCA) is comprised of both a risk assessment and risk management program, but these have developed separately and often in conflict with each other. He met with this difficulty when implementing a cohesive toxics program. In 1992 and 1994 Greenwood participated in Congressional hearings on TSCA, but Congress, in the end, did not provide a clearer agenda.

At the end of the interview, Greenwood outlines his vision and expectations for toxics reform. With REACH generating risk information, he expects EPA to focus increasingly on risk management, with or without new legislation. He discusses the importance of communicating chemical information to downstream users, as well as the political and practical feasibility of erasing the new chemicals/existing chemical distinction.

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