TSCA Work Plan Chemical Problem Formulation of Tetrabromobisphenol A and Related Chemicals Cluster

Comments from Earthjustice, Natural Resources Defense Council and Washington Toxics Coalition on Problem Formulation and Initial Assessment Documents for Three Flame Retardant Clusters

October 1, 2015 Wendy Cleland-Hamnett Director, Office of Pollution Prevention and Toxics Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington DC 20460 Re: Request for 45 Day Extension of Public Comment Period for TSCA Work Plan Chemical Problem Formulations and Initial Assessments for Three Flame Retardant Clusters, Docket IDs: EPA-HQ-OPPT-2015-0068, EPA-HQ-OPPT-2015-0081, EPA-HQ-OPPT-2014-0730 Dear Ms. Cleland-Hamnett: Earthjustice and Natural Resources Defense Council ("NRDC") submit this letter to request that the U.S. Environmental Protection Agency ("EPA") extend the public comment period for the TSCA Work Plan Chemical problem formulation and initial assessment documents for three flame retardant clusters by 45 days. This request applies to Docket ID Numbers; EPA-HQOPPT-2015-0068 (chlorinated phosphate esters cluster); EPA-HQ-OPPT-2015-0081 (cyclic aliphatic bromides cluster); and EPA-HQ-OPPT-2014-0730 (tetrabromobisphenol A and related chemicals cluster). Earthjustice and NRDC welcome EPA's important efforts to characterize the risks posed by several clusters of flame retardant chemicals that are heavily used in consumer products, leading to widespread human exposures. EPA's work related to these chemical clusters is of great importance to our organizations, and their supporters, clients, members and partners. We also welcome EPA's new approach of seeking public comment on its problem formulations and initial assessments prior to preparing draft risk assessments. Yet, the 60-day comment period does not provide us with adequate time to review these important documents and provide meaningful comments. A brief extension of the comment period is especially appropriate here given the complexity of the analyses in each of the three problem formulations and initial assessments. For each of the many chemicals covered by these assessments, there are multiple exposure routes and multiple potential endpoints for hazard. To undertake the detailed review and consultation with scientists needed to provide substantive feedback for EPA on the extensive work it has put into these documents will take longer than the 60 days allotted, especially since the first several weeks of the comment period fell during a period when many of the people who will work on our comments were on vacation. Accordingly, we ask that you extend the comment period by 45 days to December 3, 2015. Thank you very much for your consideration. We would be happy to discuss this request at your convenience. Sincerely, Eve C. Gartner Staff Attorney Earthjustice egartner@earthjustice.org Veena Singla Staff Scientist Natural Resources Defense Council vsingla@nrdc.org cc: Tala Henry, EPA Stanley Barone, EPA