Toxic Substances Control Act (TSCA) Science Advisory Committee on Chemicals (SACC) - Review of Risk Evaluation for Methylene Chloride

Comments submitted by Stephanie Schwarz, Legal Fellow, on behalf of the Environmental Defense Fund (EDF). See six attached files. Attachment 1: EDF_DCM Comments for EPA_FINAL.pdf Attachment 2: EDF Appendix I_Worker Blogs.pdf Attachment 3: EDF Appendix II_Superfund Sites Methylene Chloride.pdf Attachment 4: EDF Appendix III_Methylene Chloride Worker and ONU Risk Estimates.xlsx Attachment 5: EDF Appendix IV_Petitioners' Opening Brief.pdf Attachment 6: EDF Appendix V_Petitioners' Reply Brief.pdf

To Whom It May Concern: In addition to the 11,065 comments from Environmental Defense Fund supporters across the country, submitted to this docket on November 26th, 2019, please find attached the comments of 2,779 EDF supporters who have added their comments since that date. The comment they each submitted reads: "I am deeply concerned by the extremely flawed draft risk evaluation that EPA has released regarding methylene chloride, following on the agency's decision to allow continued use of the chemical in paint strippers in America's workplaces. Kevin Hartley was just 21 years old when he was killed while using a methylene chloride-based paint stripper to refinish a bathtub for the small, Nashville-based painting company where he worked. Today, workers like Kevin are still not adequately protected from the dangerous use of this chemical in the workplace, because the agency declined to finalize a proposed ban on commercial use of methylene chloride in paint strippers. Further -- your risk evaluation dramatically underestimates the magnitude of methylene chloride's risks, including in the following ways: * It wrongly ignores over 4 million pounds of methylene chloride annually released into air, water, and land because of a false and illegal assertion that other statutory authorities have adequately addressed them. * It assumes workers will wear fully effective personal protective equipment, despite EPA having no actual data to support this assumption. * It finds a cancer risk to workers unreasonable only if it exceeds a level of 1 in 10,000 -- which is as much as 100 times higher a risk than warrants regulation under the Toxic Substances Control Act (TSCA) to protect workers and other vulnerable subpopulations. EPA's decision to ignore many known sources of exposure and to dismiss or downplay the risks of this chemical will severely understate its actual threat to public health and jeopardize American lives. This assault on TSCA is illegal, and goes against the science that informs what we know about how chemicals like methylene chloride can affect our health and the environment. The science tells us that the combined, long-term, and even low-level exposures resulting from multiple uses and sources of exposure to a chemical are what matters. It is critical that EPA not only comprehensively assess exposures to this toxic chemical, but also immediately finalize a ban on commercial use of methylene chloride in paint strippers in order to protect the American public and workers." Please contact me if you have any questions or concerns about this submission. Sincerely, Heather Shelby Manager, Grassroots Organizing & Activism Environmental Defense Fund hshelby@edf.org

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

Comments submitted by Richard A. Denison, Ph.D., Lead Senior Scientist, on behalf of the Environmental Defense Fund (EDF). See three attached files. Attachment 1: EDF_DCM Comment_SACC Meeting FINAL.pdf Attachment 2: EDF Appendix A_Superfund Sites Methylene Chloride.pdf Attachment 3: EDF Appendix B_Methylene Chloride Worker and ONU Risk Estimates.xlsx

To Whom It May Concern: Attached, please find the signatures of 11,065 Environmental Defense Fund supporters from across the country who have submitted electronic comments concerned that with this risk evaluation, EPA has not done enough to protect Americans from methylene chloride. The comment they each submitted reads: "I am deeply concerned by the extremely flawed draft risk evaluation that EPA has released regarding methylene chloride, following on the agency's decision to allow continued use of the chemical in paint strippers in America's workplaces. Kevin Hartley was just 21 years old when he was killed while using a methylene chloride-based paint stripper to refinish a bathtub for the small, Nashville-based painting company where he worked. Today, workers like Kevin are still not adequately protected from the dangerous use of this chemical in the workplace, because the agency declined to finalize a proposed ban on commercial use of methylene chloride in paint strippers. Further -- your risk evaluation dramatically underestimates the magnitude of methylene chloride's risks, including in the following ways: * It wrongly ignores over 4 million pounds of methylene chloride annually released into air, water, and land because of a false and illegal assertion that other statutory authorities have adequately addressed them. * It assumes workers will wear fully effective personal protective equipment, despite EPA having no actual data to support this assumption. * It finds a cancer risk to workers unreasonable only if it exceeds a level of 1 in 10,000 -- which is as much as 100 times higher a risk than warrants regulation under the Toxic Substances Control Act (TSCA) to protect workers and other vulnerable subpopulations. EPA's decision to ignore many known sources of exposure and to dismiss or downplay the risks of this chemical will severely understate its actual threat to public health and jeopardize American lives. This assault on TSCA is illegal, and goes against the science that informs what we know about how chemicals like methylene chloride can affect our health and the environment. The science tells us that the combined, long-term, and even low-level exposures resulting from multiple uses and sources of exposure to a chemical are what matters. It is critical that EPA not only comprehensively assess exposures to this toxic chemical, but also immediately finalize a ban on commercial use of methylene chloride in paint strippers in order to protect the American public and workers." Please contact me if you have any questions or concerns about this submission. Sincerely, Heather Shelby Manager, Grassroots Organizing & Activism Environmental Defense Fund hshelby@edf.org