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The Toxic Substances Control Act:
from the perspective of Mark A. Greenwood

  • Born: December 18, 1951, Lansing, Michigan

  Interview Details

Interview no.: 0644
Interview Date: February 26, 2010
Location: Ropes & Gray LLP, Washington, D.C.
Interviewers: Jody A. Roberts and Kavita D. Hardy
No. of pages: 46
Minutes: 113

  Abstract of Interview

Mark Greenwood, as an undergraduate, wanted to work in government. As a law student, he discovered the emerging field of environmental law. After graduating, he joined the EPA’s Office of General Counsel and eventually became the Assistant General Counsel for Pesticides and Toxic Substances. From there Greenwood joined the newly re-named Office of Pollution Prevention and Toxic Substances as Office Director. His first challenge was recuperating from the failed asbestos rule, a demoralizing event that also effectively eliminated rule-based risk management. At the same time, he was given new tools with the Pollution Prevention Act. The office experimented with voluntary data collection and risk management initiatives, about which Greenwood drew some conclusions during the interview. From his perspective, the Toxic Substances Control Act (TSCA) is comprised of both a risk assessment and risk management program, but these have developed separately and often in conflict with each other. He met with this difficulty when implementing a cohesive toxics program. In 1992 and 1994 Greenwood participated in Congressional hearings on TSCA, but Congress, in the end, did not provide a clearer agenda.

At the end of the interview, Greenwood outlines his vision and expectations for toxics reform. With REACH generating risk information, he expects EPA to focus increasingly on risk management, with or without new legislation. He discusses the importance of communicating chemical information to downstream users, as well as the political and practical feasibility of erasing the new chemicals/existing chemical distinction.


1974 B.A., Political Science, University of Michigan
1978 M.S., Public Policy, University of Michigan
1978 J.D. University of Michigan Law School

  Professional Experience

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

1978 - 1983


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

1983 - 1987

Assistant General Counsel for the Resources Conservation and Recovery Act

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

1987 - 1988

Assistant General Counsel for Superfund

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

1988 - 1990

Assistant General Counsel for Pesticides and Toxic Substances

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

1990 - 1994

Director, Office of Pollution Prevention and Toxics

Ropes & Gray LLP, Washington, D.C.

1994 - present


Ropes & Gray LLP, Washington, D.C.

2000 - 2006

Office Managing Partner

  Table of Contents

Title and Description Page

Education and Early Career 1

Undergraduate. Law school. Environmental law. EPA Office of
General Counsel. Solid waste and hazardous materials. Toxics.

Director, Office of Pollution Prevention and Toxic Substances 8

Asbestos. Pollution Prevention Act. Existing chemicals program.
Policy experimentation. Voluntary programs. New chemicals

TSCA the Statute vs. TSCA the Movie 14

Lack of mandate. Risk assessment vs. risk management. Office of
General Counsel. Changing political agendas. Prioritization.

Toxics Reform in the 1990s 23

Congressional oversight. Lack of constituency. Risk communication. CBI.

Toxics Reform Today 29

CBI. REACH. Chemical action plans. Information disclosure to down-stream users. Existing vs. new chemical distinction. Premarket vs. premanufacture review. Shifting burden of proof.

Index 38

  About the Interviewer

Jody A. Roberts

Jody A. Roberts is the Director of the Institute for Research at the Chemical Heritage Foundation. He received his PhD and MS in Science and Technology Studies from Virginia Tech and holds a BS 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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