Title and Description Page
Education and Early Career 1
Dilemma of being an activist or academic. Professor of public administration. Desire to have experience in government. Office of Management and Budget. Return to academia. Writes book on pollution. Consultant to Ash Council and creation of Environmental Protection Agency.
Council on Environmental Quality 9
Responsibilities at Council. Drafting a proposal for chemicals legislation. Goals of pre-market clearance and burden of proof on industry.
Redrafting the Toxic Substances Control Act 10
Debates within administration. Negotiations in Congress. Transformation of law. Lack of public interest. Goal of addressing “chemical of the month syndrome.” Enactment.
Career Post-Council on Environmental Quality 14
Resources for the Future. Conservation Foundation. Environmental Protection Agency. Return to Resources for the Future. Retirement. Project on Emerging Technologies.
Implementing the Toxic Substances Control Act 21
Substantial risk notifications. State of science. Risk assessment. Lack of data. Corrosion Proof Fittings v. EPA. Unreasonable risk. Testing rule. Legal constraints. Anti-regulatory environment in government.
Toxic Substances Control Act Reform 23
Lack of initiative. European chemicals policy. Role of state regulations. Burden of proof. Nanotechnology and new chemicals. Public participation. Confidential business information.