Mark A. Greenwood

Born: December 18, 1951 | Lansing, MI, US

Mark Greenwood joined the EPA’s Office of General Counsel and eventually became the Assistant General Counsel for Pesticides and Toxic Substances.  From there Greenwood joined the newly re-named Office of Pollution Prevention and Toxic Substances as Office Director. From his perspective, the Toxic Substances Control Act (TSCA) is comprised of both a risk assessment and risk management program, but these have developed separately and often in conflict with each other. Greenwood outlines his vision and expectations for toxics reform. With REACH generating risk information, he expects EPA to focus increasingly on risk management, with or without new legislation. He discusses the importance of communicating chemical information to downstream users, as well as the political and practical feasibility of erasing the new chemicals/existing chemical distinction. 

The information listed below is current as of the date the transcript was finalized.

			

Interview Details

Interview no.: Oral History 0644
No. of pages: 40
Minutes: 113

Interview Sessions

Jody A. Roberts and Kavita D. Hardy
26 February 2010
Ropes & Gray LLP, Washington, DC

Abstract of Interview

Mark Greenwood, as an undergraduate, wanted to work in government. As a law student, he discovered the emerging field of environmental law. After graduating, he joined the EPA’s Office of General Counsel and eventually became the Assistant General Counsel for Pesticides and Toxic Substances. From there Greenwood joined the newly re-named Office of Pollution Prevention and Toxic Substances as Office Director. His first challenge was recuperating from the failed asbestos rule, a demoralizing event that also effectively eliminated rule-based risk management. At the same time, he was given new tools with the Pollution Prevention Act. The office experimented with voluntary data collection and risk management initiatives, about which Greenwood drew some conclusions during the interview. From his perspective, the Toxic Substances Control Act (TSCA) is comprised of both a risk assessment and risk management program, but these have developed separately and often in conflict with each other. He met with this difficulty when implementing a cohesive toxics program. In 1992 and 1994 Greenwood participated in Congressional hearings on TSCA, but Congress, in the end, did not provide a clearer agenda.

At the end of the interview, Greenwood outlines his vision and expectations for toxics reform. With REACH generating risk information, he expects EPA to focus increasingly on risk management, with or without new legislation. He discusses the importance of communicating chemical information to downstream users, as well as the political and practical feasibility of erasing the new chemicals/existing chemical distinction.

Education

Year Institution Degree Discipline
1974 University of Michigan BA Political Science
1978 University of Michigan MS Public Policy
1978 University of Michigan JD

Professional Experience

US Environmental Protection Agency

1978 to 1983
Attorney-Advisor
1983 to 1987
Assistant General Counsel for the Resources Conservation and Recovery Act
1987 to 1988
Assistant General Counsel for Superfund
1988 to 1990
Assistant General Counsel for Pesticides and Toxic Substances
1990 to 1994
Director, Office of Pollution Prevention and Toxics

Ropes & Gray LLP

1994 to 2011
Partner
2000 to 2006
Office Managing Partner

Table of Contents

Education and Early Career
1

Undergraduate. Law School. Environmental law. EPA Office of General Counsel. Solid waste and hazardous materials. Toxics. 

Director, Office of Pollution Prevention and Toxic Substances
8

Asbestos. Pollution Prevention Act. Existing chemicals program. Policy experimentation. Voluntary programs. New chemicals program. 

TSCA the Statute vs. TSCA the Movie
14

Lack of mandate. Risk assessment vs. risk management. Office of General Counsel. Changing political agendas. Prioritization. 

Toxics Reform in the 1990s
23

Congressional oversight. Lack of constituency. Risk communication. CBI. 

Toxics Reform Today
29

CBI. REACH. Chemical action plans. Information disclosure to down-stream users. Existing vs. new chemical distinction. Premarket vs. premanufacture review. Shifting burden of proof. 

Index
38

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.