American Chemistry Council filed 2 comments on this docket between Mar 20, 2017 and Mar 20, 2017. 10 other organizations filed here. The comment window closed 3421d ago.
The comments of the Chemical Products and Technology Division of the American Chemistry Council are attached. Steve Risotto Senior Director American Chemistry Council srisotto@americanchemistry.com
The American Chemistry Council appreciates the opportunity to comment on EPA's proposed Regulation of Certain Uses of Trichloroethylene under the Section 6 of the Toxic Substances Control Act (EPA Docket ID: EPA-HQ-OPPT-2016-0163). While ACC member companies are not engaged in the manufacturing or processing of TCE for purposes covered by the proposed rule, these comments outline some of our concerns with the proposal given its precedential nature as EPA's first section 6 risk management decision under TSCA as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act. As you will see, these comments encourage the Agency to ensure that its proposal: comports with the requirements of TSCA Section 6 and 26, which include a risk management decision consistent with the scope of the prior completed risk assessment and a requirement that all decisions be based on the best available science, among others; includes a cost-benefit analysis that satisfies regulatory guidelines and best practices as highlighted in OMB Circular A-4; and considers a comprehensive set of factors to evaluate a number of risk management approaches and options.
Section 6(a) of the Toxic Substances Control Act (TSCA) provides authority for the EPA to ban or restrict the manufacture (including import), processing, distribution in commerce, and use of chemicals, as well as any manner or method of disposal. The EPA identified trichloroethylene (TCE) for risk evaluation as part of its Work Plan for Chemical Assessments under TSCA. TCE is used in industrial and commercial processes, and also has some limited uses in consumer products. In the June 2014 TSCA Work Plan Chemical Risk Assessment for TCE, the EPA identified risks associated with commercial degreasing and some consumer uses. The EPA is proposing under section 6 of TSCA to prohibit the manufacture, processing, distribution in commerce of TCE for commercial use in aerosol degreasing and for use in spot cleaning in dry cleaning facilities; to prohibit commercial use of TCE for aerosol degreasing and for spot cleaning in dry cleaning facilities; and to require manufacturers, processors, and distributors to provide downstream notification of these prohibitions throughout the supply chain.
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