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The Toxic Substances Control Act:
from the perspective of Marilyn C. Bracken

  • Born: November 5, 1935, Pittsburgh, Pennsylvania

  Interview Details

Interview no.: 0641
Interview Date: March 5, 2010
Location: Institute of Defense Analyses, Alexandria, Virginia
Interviewers: Jody A. Roberts and Kavita D. Hardy
No. of pages: 38
Minutes: 73

  Abstract of Interview

Marilyn C. Bracken’s oral history interview begins with a discussion about the relationship between her family life and early career. Once Bracken became a mother, she transitioned out of the laboratory and began pursuing graduate work in information science. She worked for and with several government agencies before joining EPA’s Office of Toxic Substances as the deputy assistant administrator (DAA) for program information and toxic integration. Her responsibilities in program information included creating the TSCA Inventory, where the office decided to use the Chemical Abstracts Service (CAS) to assign unique identities to chemicals. She was also involved in developing Section 8 rules, and supporting industry efforts to develop internal reporting mechanisms. Internationally, she participated in Organisation for Economic Co-operation and Development (OECD) discussions to facilitate data sharing and develop a “base set” of data for new chemicals. As the DAA for toxic integration, Bracken was responsible for facilitating interagency and intra-agency data sharing. From Bracken’s perspective, EPA’s culture of stovepiping, a lack of coordination throughout the administration, and procedural burdens within TSCA severely hampered any effort to create a holistic chemicals regulation policy, and Congress was critical of EPA’s performance. After the change in administration and the arrival of Anne M. Gorsuch as administrator, Bracken left the EPA because of the lack of administrative support.

Bracken believes that TSCA was unique in its authority to be a regulatory catchall with the ability to prevent pollution before it happened. She emphasized the role that access to information, both by the government and the public, plays in effectively carrying out that authority. She discussed the challenge that nanotechnology presents to the CAS system of chemical identity that she developed. Bracken argues that the procedural burdens to EPA action must also be addressed in a TSCA reform process, specifically proving “unreasonable risk” and the limitations around confidential business information (CBI). She concludes with a discussion of the changing language of “safety,” and the significance of the Office of Prevention, Pesticides and Toxic Substances changing its name to the Office of Chemical Safety and Pollution Prevention.

  Education

1957 B.S., Chemistry, Carnegie Institute of Technology
1967 M.A., Public Administration: Technology of Management, American University
1971 Ph.D., Public Administration: Technology of Management, American University

  Professional Experience

Melpar, Inc., Falls Church, Virginia

1957 - 1958

Chemist

National Bureau of Standards, Washington, D.C.

1962 - 1964

Chemist

Department of Agriculture, Washington, D.C.

1971 - 1973

Information Systems Analyst, Office of Information Systems

Consumer Product Safety Commission, Washington, D.C.

1973 - 1976

Division Director, Division of Scientific Coordination, Bureau of Biomedical Sciences

The MITRE Corporation, McLean, Virginia

1976 - 1977

Associate Department Head, Environmental Chemistry and Biology

The MITRE Corporation, McLean, Virginia

1977 - 1978

Department Head, Energy and Environmental Information Systems

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

1978 - 1980

Deputy Assistant Administrator for Program Integration and Information, Office of Pesticides and Toxic Substances

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

1980 - 1983

Associate Assistant Administrator for Toxics Integration, Office of Pesticides and Toxic Substances

Environmental Testing and Certification Corporation, Edison, New Jersey

1983 - 1988

Vice President of Product Testing and Liability

Metcalf and Eddy, Wakefield, Massachusetts

1988 - 1989

Senior Vice President for Special Projects

Metcalf & Eddy de Puerto Rico, Inc., San Juan, Puerto Rico

1988 - 1991

President

Air and Water Technologies, Inc., Miami, Florida

1991 - 1992

President, South Region

Air and Water Technologies, Inc., Washington, D.C.

1992 - 1993

Senior Vice President, Federal Programs

Paragon Global Services, Ltd., Fairfax, Virginia

1993 - 1994

President

Applied Biosciences International, Inc., Fairfax, Virginia

1993 - 1994

Vice President, Marketing and Business Development

Bracken Associates, LLC, Washington, D.C.

1994 - present

President and General Manager

Institute for Defense Analyses, Alexandria, Virginia

1996 - 2005

Adjunct Research Staff Member, Systems Evaluation Division

Institute for Defense Analyses, Alexandria, Virginia

2005 - present

Adjunct Research Staff Member, Operations Evaluation Division

  Honors

1966 - 1970

National Institutes of Health Graduate Trainee Fellowship

1976

Chairman’s Special Citation, U.S. Consumer Product Safety Commission

1978

Distinguished Alumna Award, American University

1980

Presidential Rank Award, Meritorious Executive, U.S. Government

1981

Fellow, American Association for Advancement of Science

2002

Fellow, Society of American Military Engineers

  Table of Contents

Title and Description Page

Education, Early Career, and Family Life 1

Chemistry. Children. NIH grant in information science. Department of Agriculture. Consumer Product Safety Commission. MITRE
Corporation.

Office of Toxic Substances: Program Information 2

TSCA Inventory. Use of CAS system. Development of Section 8 rules. Industry reporting mechanisms. International development of a “base set” for new chemicals.

Office of Toxic Substances: Toxics Integration 12

Interagency cooperation. Prioritization. Section 9. Lack of mandate.
Procedural hurdles. EPA culture of stovepiping. Interagency Testing
Committee.

Implementation and Leaving EPA 18

Science of structure-activity relationships. Congressional oversight. Lack of administrative support.

Toxic Substances Control Act Reform 21

Pollution prevention. Information as the key to regulation.
Nanotechnology. CBI. Procedural hurdles. “Unreasonable risk” vs.
“safety.”

Index 29

  About the Interviewer

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.

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