Oral history interview of the toxic substances control act from the perspective of Marilyn C. Bracken
- 2010-Mar-05
This oral history is one in a series that looks at the history of the Toxic Substances Control Act from the perspectives of the individuals involved in its creation, implementation, and execution.
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.
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About the Interviewers
Jody A. Roberts served as 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 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.
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Interviewee biographical information
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Education
| Year | Institution | Degree | Discipline |
|---|---|---|---|
| 1957 | Carnegie Institute of Technology | BS | Chemistry |
| 1967 | American University (Washington, D.C.) | MA | Public Administration: Technology of Management |
| 1971 | American University (Washington, D.C.) | PhD | Public Administration: Technology of Management |
Professional Experience
Melpar, Inc.
- 1957 to 1958 Chemist
United States. National Bureau of Standards
- 1962 to 1964 Chemist
United States. Department of Agriculture
- 1971 to 1973 Information Systems Anaylst
U.S. Consumer Product Safety Commission
- 1973 to 1976 Division Director, Division of Scientific Coordination, Bureau of Biomedical Sciences
Mitre Corporation
- 1976 to 1977 Associate Department Head, Environmental Chemistry and Biology
- 1977 to 1978 Department Head, Energy and Environmental Information Systems
United States. 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
- 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 Analyses
- 1996 to 2005 Adjunct Research Staff Member, Systems Evaluation Division
- 2005 to 2011 Adjunct Research Staff Member, Operations Evaluation Division
Honors
| Year(s) | Award |
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| 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 |
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