Who was responsible for the Kepone Incident? I believe Allied Signal ("Allied") and Life Sciences Corporation ("Life Sciences") bear most of the responsibility. Allied Signal had reason to trust Life Sciences since two former employees were involved in the manufacturing process. However, Allied Signal had an overall responsibility to ensure that Life Sciences Corp. manufactured the ant and roach bait pesticide in an efficacious manner. Life Sciences was allowed to continue to produce Kepone under such horrific conditions for sixteen months! The township of Hopewell had a responsibility to notify Federal authorities for the Life Sciences violations.
If you were to choose between TSCA and TPR which would you prefer and why? Allied should implement TPR immediately! As a former pharmaceutical manufacturing supervisor I could not imagine operating without a standard operating procedure. The safety of employees and the public should be considered the highest priority! A slight deviation in a blending process, for example, could change the properties of the final product.
While I had an incredible amount of paperwork to review after each batch I never once thought it was an exercise in bureaucracy. I agree with Merrill when he argued that TPR would accomplish more good than harm. Furthermore, one could argue that Allied should be doing more than what the government requires. They are in no position to cut corners after the Kepone incident. Implement TPR and support TSCA no questions asked. Follow Dow's lead and assume responsibility for your actions.