Title and Description Page
Early career 1
Chemical engineering. Law school. Federal-state relations. Law clerkships. President’s Council on Environmental Quality. Creation of the U.S. Environmental Protection Agency.
Drafting the Toxic Substances Control Act 5
Legal models. Premarketing review. Imminent hazard provision. Not prescriptive.
Implementation of the Toxic Substances Control Act 9
Utility of ambiguity. Need for conceptual vision. Other legislative models. Use restrictions.
Interagency Negotiations 18
Office of Management and Budget approval. Preemption. Citizen suits. Judicial review. Penalties. Confidentiality. Responsibility for testing. Not impeding technological innovation.