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The Toxic Substances Control Act:
from the perspective of Steven D. Jellinek

  • Born: May 22, 1940, Brooklyn, New York

  Interview Details

Interview no.: 0653
Interview Date: January 29, 2010
Location: The Chemical Heritage Foundation, Philadelphia, Pennsylvania
Interviewers: Jody A. Roberts and Kavita D. Hardy
No. of pages: 34
Minutes: 96

  Abstract of Interview

Steven D. Jellinek received a bachelor’s degree in political science from the University of Rochester and a master’s degree in public affairs from Syracuse University before accepting a position at the Internal Revenue Service.  He was at the Internal Revenue Service for several years before being invited to work with the newly established Council on Environmental Quality.  Once the Toxic Substances Control Act (TSCA) was passed, he became the first Assistant Administrator for Toxic Substances at the U.S. Environmental Protection Agency, and soon the Assistant Administrator for Pesticides and Toxic Substances.  The position was expected to be challenging: TSCA was written with many procedural hurdles and the environmental Congressional committees were not eager to oversee its implementation.  The law quickly became an “orphan” in Congress.

Jellinek encountered many challenges in implementing the new law: there was no inventory rule and no classificatory system for chemicals; there were interagency politics that had to be negotiated; there was little statutorial guidance for prioritizing exiting chemicals, or even defining a chemical of concern; and there were no technologies of risk assessment or toxicity testing.  The Office of General Counsel advised caution in exercising the new law, and industry was quick to challenge EPA rules.  Jellinek inherited what was considered an inefficient organizational structure in the Office of Toxic Substances.  The premanufacturing review process was one of the few immediate successes; industry seemed to really internalize the goal of safer new chemicals.  Maintaining confidential business information proved to be a burden to a more effective chemicals program. 

Jellinek believes that it is the responsibility of policymakers to be precautionary.  He repeatedly questioned his decision as assistant administrator not to pressure Congress for a more workable law.  From his perspective, a reformed TSCA should strive to reduce the hurdles on EPA action, and he also thinks it might be worth considering a premarket rather than a premanufacture review.   


1960 B.A., Political Science, University of Rochester
1961 M.P.A. Syracuse University

  Professional Experience

Internal Revenue Service, Washington, D.C.

1961 - 1967

Various staff positions

Internal Revenue Service, Washington, D.C.

1968 - 1971

Special Assistant to the Assistant Commissioner for Compliance

Council on Environmental Quality, Executive Office of the President, Washington, D.C.

1971 - 1972

Staff Member

Council on Environmental Quality, Executive Office of the President, Washington, D.C.

1972 - 1973

Senior Staff Member

Council on Environmental Quality, Executive Office of the President, Washington, D.C.

1973 - 1977

Staff Director

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

1977 - 1981

Assistant Administrator for Pesticides and Toxic Substances

Jellinek, Schwartz & Connolly, Inc., Washington, D.C.

1981 - 2000


Dow AgroSciences, Zionsville, Indiana

1994 - 2004

Member, Global Environmental Advisory Committee

OMI Corporation, Stamford, Connecticut

1996 - 2000

Member, Board of Directors

The Scotts Miracle-Gro Company, Marysville, Ohio

2001 - present

Member, Innovation and Technology Advisory Board


1969 - 1970

National Institute of Public Affairs Fellowship, Stanford University, Palo Alto, California

  Table of Contents

Title and Description Page

Education and Early Career 1

Public administration.  Internal Revenue Service.  President’s Council on Environmental Quality.  U.S. Environmental Protection Agency.

Perceptions of the new Toxic Substances Control Act 4

Political difficulties.  Procedural hurdles.  Reorganizing the Office of Toxic Substances.  Absence of congressional advocates.

Implementing the Toxic Substances Control Act 6

Inventory rule.  Naming chemicals.  Interagency Testing Committee recommendations.  Prioritization.  Defining unreasonable risk.  General Counsel.  Premanufacturing notices.  Office organization.  Confidential business information.  Lack of mandate.  Risk assessment and toxicity testing.

The Inevitability of Being Wrong 17

Precaution versus the “precautionary principle.”  Asbestos.

Toxic Substances Control Act Reform 22

Reduce procedural hurdles.  Premarket versus premanufacture review.  Prolonged Congressional oversight.

Index 26

  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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