Marilyn C. Bracken

Born: November 5, 1935 | Pittsburgh, PA, US

Marilyn C. Bracken worked for and with several government agencies before joining EPA’s Office of Toxic Substances as the deputy assistant administrator for program information and toxic integration. Her responsibilities in program information included creating the TSCA Inventory, where the office decided to use the Chemical Abstracts Service (CAS) to assign unique identities to chemicals. She was also involved in developing Section 8 rules, and supporting industry efforts to develop internal reporting mechanisms.  Internationally, she participated in Organisation for Economic Co-operation and Development (OECD) discussions to facilitate data sharing and develop a “base set” of data for new chemicals. Bracken believes that TSCA was unique in its authority to be a regulatory catchall with the ability to prevent pollution before it happened.  

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Interview Details

Interview no.: Oral History 0641
No. of pages: 31
Minutes: 73

Interview Sessions

Jody A. Roberts and Kavita D. Hardy
5 March 2010
Institute for Defense Analyses, Alexandria, Virginia

Abstract of Interview

Marilyn C. Bracken’s oral history interview begins with a discussion about the relationship between her family life and early career. Once Bracken became a mother, she transitioned out of the laboratory and began pursuing graduate work in information science. She worked for and with several government agencies before joining EPA’s Office of Toxic Substances as the deputy assistant administrator (DAA) for program information and toxic integration. Her responsibilities in program information included creating the TSCA Inventory, where the office decided to use the Chemical Abstracts Service (CAS) to assign unique identities to chemicals. She was also involved in developing Section 8 rules, and supporting industry efforts to develop internal reporting mechanisms. Internationally, she participated in Organisation for Economic Co-operation and Development (OECD) discussions to facilitate data sharing and develop a “base set” of data for new chemicals. As the DAA for toxic integration, Bracken was responsible for facilitating interagency and intra-agency data sharing. From Bracken’s perspective, EPA’s culture of stovepiping, a lack of coordination throughout the administration, and procedural burdens within TSCA severely hampered any effort to create a holistic chemicals regulation policy, and Congress was critical of EPA’s performance. After the change in administration and the arrival of Anne M. Gorsuch as administrator, Bracken left the EPA because of the lack of administrative support.

Bracken believes that TSCA was unique in its authority to be a regulatory catchall with the ability to prevent pollution before it happened. She emphasized the role that access to information, both by the government and the public, plays in effectively carrying out that authority. She discussed the challenge that nanotechnology presents to the CAS system of chemical identity that she developed. Bracken argues that the procedural burdens to EPA action must also be addressed in a TSCA reform process, specifically proving “unreasonable risk” and the limitations around confidential business information (CBI). She concludes with a discussion of the changing language of “safety,” and the significance of the Office of Prevention, Pesticides and Toxic Substances changing its name to the Office of Chemical Safety and Pollution Prevention.

Education

Year Institution Degree Discipline
1957 Carnegie Institute of Technology BS Chemistry
1967 American University MA Public Administration: Technology of Management
1971 American University PhD Public Administration: Technology of Management

Professional Experience

Melpar, Inc.

1957 to 1958
Chemist

National Bureau of Standards

1962 to 1964
Chemist

US Department of Agriculture

1971 to 1973
Information Systems Anaylst

Consumer Product Safety Commission

1973 to 1976
Division Director, Division of Scientific Coordination, Bureau of Biomedical Sciences

The MITRE Corporation

1976 to 1977
Associate Department Head, Environmental Chemistry and Biology
1977 to 1978
Department Head, Energy and Environmental Information Systems

US Environmental Protection Agency

1978 to 1980
Deputy Assistant Administrator for Program Integration and Information, Office of Pesticides and Toxic Substances
1980 to 1983
Associate Assistant Administrator for Toxics Integration, Office of Pesticides and Toxic Substances

Environmental Testing and Certification Corporation

1983 to 1988
Vice President of Product Testing and Liability

Metcalf & Eddy

1988 to 1989
Senior Vice President for Special Projects

Metcalf & Eddy de Puerto Rico, Inc.

1988 to 1991
President

Air and Water Technologies, Inc.

1991 to 1992
President, South Region
1992 to 1993
Senior Vice President, Federal Programs

Paragon Global Services, Ltd.

1993 to 1994
President

Applied Biosciences International, Inc.

1993 to 1994
Vice President, Marketing and Business Development

Bracken Associates, LLC

1994 to 2011
President and General Manager

Institute for Defense Anaylses

1996 to 2005
Adjunct Research Staff Member, Systems Evaluation Division
2005 to 2011
Adjunct Research Staff Member, Operations Evaluation Division

Honors

Year(s) Award
1966 to 1970

National Institutes of Health Graduate Trainee Fellowship

1976

Chairman’s Special Citation, US Consumer Product Safety Commission

1978

Distinguished Alumna Award, American University

1980

Presidential Rank Award, Meritorious Executive, US Government

1981

Fellow, American Association for Advancement of Science

2002

Fellow, Society of American Military Engineers

Table of Contents

Education, Early Career, and Family Life
1

Chemistry. Children. NIH grant in information science. Department of Agriculture. Consumer Product Safety Commission. MITRE Corporation. 

Office of Toxic Substances: Program Information
2

TSCA Inventory. Use of CAS system. Development of Section 8 rules. Industry reporting mechanisms. International development of a “base set” for new chemicals

Office of Toxic Substances: Toxics Integration
12

Interagency cooperation. Prioritization. Section 9. Lack of mandate. Procedural hurdles. EPA culture of stovepiping. Interagency Testing Committee.

Implementation and Leaving EPA
18

Science of structure-activity relationships. Congressional oversight. Lack of administrative support.

Toxic Substances Control Act Reform
21

Pollution prevention. Information as the key to regulation. Nanotechnology. CBI. Procedural hurdles. “Unreasonable risk” vs. “safety.”

Index
29

About the Interviewer

Jody A. Roberts

Jody A. Roberts is the Director of the Institute for Research at the Science History Institute. 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 was a research assistant in the Environmental History and Policy Program at the Chemical Heritage Foundation. She received a BA in chemistry and in economics from Swarthmore College.