When President Gerald Ford signed the Toxic Substances Control Act (TSCA) into law in 1976, he declared it “one of the most important pieces of environmental legislation . . . enacted by the Congress,” one that would “close a gap in our current array of laws to protect the health of our people and the environment.” History has not been kind to President Ford’s prediction. Throughout its 37-year implementation period, commentators have cited TSCA more for its shortcomings than for its accomplishments, and the public literature is replete with papers, arguments, and opinions on the need to reform, modernize, or revolutionize federal chemical control policy.