The Toxic Substances Control Act:
from the perspective of Charles M. Auer

Charles M. Auer joined the EPA’s Office of Toxic Substances, before the Toxic Substances Control Act (TSCA) was passed, as an entry level chemist doing screening-level risk assessments. He was the first chair of the Structure Activity Team, which was responsible for developing structure activity relationship (SAR) analysis as a method for evaluating new chemicals. While it was clear to Auer that there was never any question that SAR satisfied the legal requirements of TSCA’s Section 4 premanufacture review, he witnessed several studies to verify the validity of SAR results, including a joint effort between the EPA and European Union in the early 1990s. By this time Auer was Director of the Existing Chemical Assessment Division, where SARs were not as heavily relied upon. As a division director, Auer found it difficult to prioritize existing chemicals, primarily because Inventory Update Rules were not issued to collect changing hazard and exposure information; the EPA attempted other, more voluntary methods to collect data, to varying degrees of success.

Auer believes that the Office has been very innovating, adjusting to emerging science on toxicity and applying TSCA while staying within its legal limits, and that the key to an effective toxics program is to be as dynamic as the chemical industry.

U.S. Environmental Protection Agency, Washington, D.C.

1976 - 1985

Staff chemist, Office of Toxic Substances

U.S. Environmental Protection Agency, Washington, D.C.

1985 - 1988

Section Chief, Metabolism and Structure Activity Section, Office
of Toxic Substances

U.S. Environmental Protection Agency, Washington, D.C.

1985 - 1988

Branch Chief, New Chemicals Assessment Branch, Office of
Toxic Substances

U.S. Environmental Protection Agency, Washington, D.C.

1988 - 1989

Deputy Director, Health and Environmental Review Division,
Office of Toxic Substances

U.S. Environmental Protection Agency, Washington, D.C.

1989 - 1992

Director, Existing Chemical Assessment Division, Office of
Pollution Prevention and Toxics

U.S. Environmental Protection Agency, Washington, D.C.

1992 - 2002

Director, Chemical Control Division, Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency, Washington, D.C.

2002 - 2009

Director, Office of Pollution Prevention and Toxics

Charles Auer and Associates, Poolesville, Maryland

2009 - present

President

Bergeson & Campbell, P.C., Washington, D.C.

2009 - [resent

Affiliate

Jody A. Roberts

Jody A. Roberts is the Associate Director for the Center for Contemporary History and Policy and the Manager of the Environmental History and Policy Program at the Chemical Heritage Foundation. Roberts received his Ph.D. and M.S. in Science and Technology Studies from Virginia Tech and holds a B.S. in Chemistry from Saint Vincent College. His research focuses on the intersections of regulation, innovation, environmental issues, and emerging technologies within the chemical sciences.

Kavita D. Hardy

Kavita D. Hardy is a research assistant in the Environmental History and Policy Program at the Chemical Heritage Foundation. She received a B.A. in Chemistry and in Economics from Swarthmore College.