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.
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
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
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.