Comment on Using Competition-Based Regulation to Bridge the Toxics Data Gap

摘要

In her Article, Prof. Wendy Wagner takes on one of the core challenges of U.S. chemical management policy: how to assure that useful toxicity data is generated about chemicals in commerce. She offers a creative proposal for harnessing competitive instincts in companies to assure that such data are developed. As described below, there are important questions about whether this proposal will actually work in practice. At the same time, the history of chemical regulation in the United States has taught us that our assumptions about how the market will respond to specific regulatory policies are often wrong.