The time for TSCA reform is basically now or never. The emerging framework of chemical management from other countries and U.S. states may or may not need to be steered in a new direction or aligned in a more systematic and coherent way by federal legislation. At some point, the policies and practice of the emerging chemical management system will settle into a new equilibrium, perhaps making congressional action a disruptive activity. If, however, there is consensus that federal reform would be beneficial, then it should only proceed with a clear agenda, provision of the necessary resources, establishment of risk-based priorities, protection of the ability to innovate, a balance of burden shifting, avoidance of the new versus existing chemical trap, and by addressing the role of states.
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