IRIS Assessment Materials for Ammonia and Ammonium Salts

The Fertilizer Institute (TFI), on behalf of its member companies, submits the attached comments addressing the U.S. Environmental Protection Agencys (EPA) request for comment entitled Availability of the IRIS Assessment Plan for Ammonia and Ammonium Salts: Noncancer Assessment for Oral Exposure (hereinafter IRIS Assessment Plan). The IRIS Assessment Plan, identified by EPA for comment in the Federal Register on April 16, 2018, appears at 83 Fed. Reg. 16,356. TFI represents the nations fertilizer industry, including producers, importers, retailers, wholesalers and companies that are engaged in all aspects of the fertilizer supply chain. Fertilizer is a key ingredient in feeding a growing global population, which is expected to surpass 9.5 billion people by 2050. Half of all food grown around the world today is made possible through the use of fertilizer. In 2016 alone, the U.S. fertilizer industry invested $4.3 billion in capital infrastructure projects. These investments create jobs, increase worker and community safety, and help conserve energy, land, water, and air resources. The U.S. fertilizer industry is one of the worlds largest. The United States is the worlds fourth largest producer of nitrogen-based fertilizers. TFI members produced 15.7 million tons of ammonia (CAS # 7664-41-7) in 2017. TFI members also use ammonia to produce other nitrogen fertilizer products, such as urea, ammonium nitrate, and urea ammonium nitrate (UAN) solution. TFI and its members have technical expertise in the chemical, physical, and toxicological properties of ammonia. And so TFI and its members have a strong interest in EPAs review of the scientific literature and the risk assessment procedures used to revise the ammonia IRIS risk assessment.