Documents for the Stockholm Convention on Persistent Organic Pollutants Review Committee

January 22, 2008 Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460?0001 Attention: Docket ID Number EPA?HQ?OPPT?2006?0794; FRL?8345-6 On behalf of the American Chemistry Council (The Council) and its Chlorine Chemistry Division, we appreciate the opportunity to provide input for the development of the draft risk profiles and draft risk management evaluations being developed by ad hoc working groups of the POPs Review Committee (POPRC) under the Stockholm Convention on Persistent Organic Pollutants (POPs). These comments relate to the following POPRC documents and issues: 1.General policy comments regarding the draft risk profiles and draft risk management evaluations for the candidate chemicals being considered under the Stockholm POPs Convention. 2.Specific Annex F information for pentachlorobenzene. The attached comments emphasize the following: ?The risk profiles developed for candidate chemicals and the POPRC?s decisions regarding those risk profiles must assess the actual risk of a chemical. Many of the final risk profiles and the POPRC?s decisions regarding those risk profiles did not fully consider the inherent risk-based requirements of the Convention. ?Many of the risk profiles failed to accurately assess whether a chemicals is ?likely as a result of its long-range environmental transport to lead to significant adverse human health and/or environmental effects, such that global action is warranted.? The POPRC, in seeking to evaluate whether a chemical is ?likely to have significant adverse effects as a result of long-range environmental transport, such that global action is warranted? should consider key elements outlined in the Convention text and by the POPRC itself. ?An analysis of the pentachlorobenzene (PeCB) nomination, existing scientific literature, and available evidence (both trend information and the evaluation of levels in the environment/tissues) does not indicate that PeCB meets the criterion for significant adverse effects as a result of long-range transport. While we do not believe that PeCB should be considered further by the POPRC, we are providing the requested Annex F information to further inform the POPRC?s evaluation of this substance. In addition, we would like to reiterate our continued concern regarding the lack of scientific rigor and the failure by the POPRC to fully consider the inherent risk- based requirements contained in the Convention. This issue was a matter of significant debate at the 3rd meeting of the POPRC and should receive the utmost attention by governments and the Conference of the Parties when it considers possible additions to the Convention. Finally, we would also like to indicate our general support for the comments filed by the chlorinated paraffins industry and the semiconductor industry. The American Chemistry Council was significantly engaged in the negotiations of the Stockholm Convention, and we remain committed to its reasonable implementation. We also fully appreciate the difficult position the U.S. government is in as an observer to the POPRC proceedings, rather than a full party to the Stockholm Convention. We offer the attached comments to help clarify and improve the quality of the POPRC?s work and to provide information to the U.S. government to help inform its review of these draft documents. If there are any questions regarding these comments, please contact Robert Simon at robert_simon@americanchemistry.com or 703-741-5866. Sincerely, Robert J. Simon Managing Director American Chemistry Council Chlorine Chemistry Division

Ellie Clark/DC/USEPA/US 07/03/2007 02:08 PMTo oppt.ncic@epa.gov cc bcc Subject Fw: ACC Comments on POPs Draft RPs and RMEs Please include these late comments in docket EPA-HQ-2006-0794 phase 3 for the comment period that closed on June 22, 2007. Thanks. Ellie Clark OPPT/CCD/ECB 202-564-2962 ----- Forwarded by Ellie Clark/DC/USEPA/US on 07/03/2007 02:06 PM ----- "Simon Jr., Robert J." <Robert_Simon@americanchemistry.com> 06/27/2007 11:37 AM To "Alan Rush" <rushac@state.gov>, Paul Almodovar/RTP/USEPA/US@EPA, <bednarekat@state.gov>, <Blandine_Trouille@ita.doc.gov>, Chris Blunck/DC/USEPA/US@EPA, Ellie Clark/DC/USEPA/US@EPA, <Jennifer_Prescott@USTR.EOP.GOV>, Rhea Jones/RTP/USEPA/US@EPA, <marinosw@state.gov>, Bruce Rodan/DC/USEPA/US@EPA, Kimber Scavo/RTP/USEPA/US@EPA, "Susan Gardner" <gardners@state.gov>, <ThompsonJE2@state.gov> cc Amy Breedlove/DC/USEPA/US@EPA Subject ACC Comments on POPs Draft RPs and RMEs Please find attached ACC's comments on the draft draft risk profiles and draft risk management evaluations being developed by ad hoc working groups of the POPs Review Committee (POPRC) under the Stockholm Convention on Persistent Organic Pollutants (POPs). We were unable to file these electronically. Thanks, Rob Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460–0001 Attention: Docket ID Number EPA–HQ–OPPT–2006–0794; FRL–8130–9 On behalf of the American Chemistry Council (The Council) and its Chlorine Chemistry Division, we appreciate the opportunity to provide feedback on the draft risk profiles and draft risk management evaluations being developed by ad hoc working groups of the POPs Review Committee (POPRC) under the Stockholm Convention on Persistent Organic Pollutants (POPs). These comments relate to the following POPRC documents and issues: 1. General policy comments regarding the draft risk profiles and draft risk management evaluations for the ten candidate chemicals being considered under the Stockholm POPs Convention. 2.Specific Annex E information and comments on the draft risk profile for pentachlorobenzene. We would also like to indicate our general support for the comments filed by 3M Company, the Bromine Science & Environment Forum (BSEF), the chlorinated paraffins industry and the semiconductor industry. The American Chemistry Council was significantly engaged in the negotiations of the Stockholm Convention, and we remain committed to its reasonable implementation. We also fully appreciate the difficult position the U.S. government is in as an observer to the POPRC proceedings, rather than a full party to the Stockholm Convention. We offer the attached comments to help clarify and improve the quality of the POPRC’s work and to inform the U.S. government’s position for the review of these draft documents. If there are any questions regarding these comments, please contact Robert Simon at robert_simon@americanchemistry.com or 703-741-5866.

Filed on regulations.gov — full text not in the inline record.

October 31, 2006 Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460?0001 Attention: Docket ID Number EPA?HQ?OPPT?2006?0794. On behalf of the American Chemistry Council (The Council) and its Chlorine Chemistry Division, we appreciate the opportunity to provide input on the documents and issues expected to be discussed at the second meeting of the POPs Review Committee (POPRC) under the Stockholm Convention on Persistent Organic Pollutants (POPs). These comments relate to the following POPRC documents and issues: 1.Consideration of proposals for five new chemicals to be considered for addition to the Convention at the November 2006 POPRC meeting. 2.Consideration of draft risk profiles for chemicals previously proposed in November 2005 for addition to the Stockholm Convention. 3.Listing of chemicals the transformation products of which are chemicals proposed for listing in Annexes A, B or C of the Convention. 4.Standard work plan for the preparation of a draft risk profile and a draft risk management evaluation. 5.Draft risk management evaluation outline. 6.Confidentiality arrangements. The American Chemistry Council was significantly engaged in the negotiations of the Stockholm Convention, and we remain committed to its rational implementation. We offer the attached comments to help clarify and improve the quality of the POPRC?s work and to inform the U.S. government?s position for the upcoming POPRC meeting. If there are any questions regarding these comments, please contact Robert Simon at robert_simon@americanchemistry.com or 703-741-5866.