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• Consolidate non-core functions (communications, economists, congressional relations, etc.) into one OLEM suboffice to allow the subjectmatter offices to focus on the execution of field work.

• Eliminate the Office of Emergency Management and reassign its functions.

1. Move the emergency management function (currently OEM) into Homeland Security under the Administrator’s office.

2. Incorporate removal authority (currently OEM) into OSRTI.

3. Retain the oversight and enforcement of the RMP program within OLEM.

4. Drop “Emergency Management” from OLEM’s name.

Budget

While the overall goal is certainly to reduce government scope and spending, OLEM’s programs present the best opportunity to use taxpayer dollars to execute EPA’s core mission of cleaning up contamination.

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION (OCSPP)

OCSPP primarily oversees the regulation of new and existing chemicals under the Toxic Substances Control Act (TSCA)* and the regulation of pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)*” and Federal Food, Drug, and Cosmetic Act (FFDCA).”° These activities are managed in two separate offices within OCSPP: the Office of Pollution Prevention and Toxics (OPPT, chemicals) and Office of Pesticide Programs (OPP, pesticides). OCSPP is constantly pressured to ban the use of certain chemicals, typically based on fear as a result of mischaracterized or incomplete science.

Needed Reforms and New Policy in OPPT (Chemicals)

• Ensure that decision-making is risk-based rather than defaulting to precautionary, hazard-based approaches like the Integrated Risk Information System (IRIS).

• Focus the scope of chemical evaluations on pathways of exposure that are not covered by other program offices and other environmental statutes, and eliminate scope creep to ensure that evaluations can be completed ina timely manner consistent with the statutory requirements.