I think the short answer is that on the spectrum of statutes or regulatory regimes that address the issue of toxic substances, laws like CEPA and the American Toxic Substances Control Act are much more risk-driven than is the situation in Europe under REACH, which is much more hazard-driven.
In my respectful submission, given the nature and the quantity of chemicals that are being generated globally and in this country, we need a much more hazard-based regime to address the challenges, and not a risk-based regime, which is predominantly what we have now.