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OPA-76-12 1 (1975-12-04)

handle is hein.gao/gaobaagwe0001 and id is 1 raw text is: COMPTROLLER GENERAL OF THE UNITED STATES WASHINGTON. D.C. 20548 B-109650 DEC 4 1975 The Honorable John V. Tunney United States Senate Dear Senator Tunney: 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 of 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. The cost estimates presented in the MCA study were significantly higher than those made by the Environmental Protection Agency (EPK) in its Draft Economic Impact Assessment for the Proposed Toxic Substances Control Act S. 776, dated June 1975. We believe that the basic issues are: i. Estimates of the number of chemicals to be tested and the testing costs per chemical; 2. The maintenance of innovation cost; 3. The methods of data collection for the MCA report; and 4. The economic impact estimates. Each of these will be discussed in turn. 1. Estimates of the Number of Chemicals to be Tested and the Testing Costs Per Chemical In our staff study, we pointed out that the three studies of the TSCA differed substantially in their estimates of costs of testing. We said that the EPA cost figures were based on assumptions that seemed to be the most consistent with the TSCA requirements, but we also pointed out areas OPA-76-12

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