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# Chemical Producers and Distributors Association

*1730 Rhode Island Avenue, N.W.*

*Suite 812*

*Washington, D.C. 20036*

*202.386.7407*

*FAX: 202.386.7409*

January 14, 2008

*[Via U.S. Mail and Email]{.underline}*: <wooge.william@epa.gov>

<phillips.linda@epa.gov>

Docket No. EPA-HQ-OPPT-2007-1080

Docket No. EPA-HQ-OPPT-2007-1081

William E. Wooge

Office of Science Coordination and Policy (7201M)

U.S. Environmental Protection Agency

1200 Pennsylvania Ave., N.W.

Washington, D.C. 20460-0001

**Re: Request for Comment Period Extensions for (1) EDSP Draft Policies
and Procedures for Initial Screening EPA-HQ-OPPT-2007-1080; and (2)
related Information Collection Request (EPA ICR No. 2249.01)
EPA-HQ-OPPT-2007-1081**

Dear Mr. Wooge:

The Chemical Producers & Distributors Association (CPDA) is a
not-for-profit trade association that represents companies engaged in
the formulation, manufacture, distribution, and sale of crop protection
chemicals used on food, feed, and fiber crops and in the care and
maintenance of lawns, gardens, turf, and ornamentals. Many of our
members are involved in the development and distribution of adjuvants
and inert ingredients used to increase the efficacy of crop protection
formulations. Consequently, many EPA rules, regulations, and guidelines
affect our member companies significantly.

CPDA would like to express its gratitude to EPA for granting additional
time to comment on the Agency's proposed list of chemicals selected for
Tier-1 screening under the Endocrine Disruptor Screening Program (EDSP)
(*Draft List of Initial Pesticide Active Ingredients and Pesticide
Inerts to be Considered for Screening Under the Federal Food, Drug, and
Cosmetic Act;* 72 Fed. Reg. 33486, June 18, 2007). Although CPDA is not
seeking further extension of the comment period on the draft list of
chemical candidates for screening, we are requesting 90-day extensions
of the comment periods for each of the following related regulatory
actions:

1.  *Endocrine Disruptor Screening Program (EDSP); Draft Policies and
    Procedures for Initial Screening; Request for Comment;*
    EPA-HQ-OPPT-2007-1080. 72 Fed. Reg. 70842 (December 13, 2007); and

2.  *Agency Information Collection Activities; Proposed Collection;
    Comment Request; Tier 1 Screening of Certain Chemicals Under the
    Endocrine Disruptor Screening Program (EDSP); EPA ICR No. 2249.01,
    OMB Control No. 2070-new.* EPA-HQ-OPPT-2007-1081. 72 Fed. Reg. 70839
    (December 13, 2007) (the "ICR").

The comment periods for these notices are scheduled to end on February
11, 2008. CPDA respectfully requests that EPA extend the comment period
for these initiatives until Monday, May 12, 2008. CPDA does not wish to
delay implementation of the EDSP. However, EPA's proposed policies and
procedures for implementing that program present a complex,
precedent-setting process for requiring the testing of certain chemical
substances. This will require careful analysis and a thorough
understanding of EPA's proposed approach prior to rendering meaningful
comments to the Agency. In addition, EPA has asked for input on multiple
specified categories of questions, many of which involve complex issues
that will also require careful analysis and deliberation.

Moreover, EPA's draft EDSP document proposes a complex cost sharing and
data compensation scheme, procedures for handling confidential business
information, notification procedures, a mechanism for seeking an
exemption, a process for contesting test orders, and a number of other
provisions. EPA has also invited comment on due process procedural
issues, and is seeking input on how best to identify potential
recipients of test orders. These are complicated issues that will have a
far-reaching impact on the inert and pesticide industries, significantly
affecting inert manufacturers and importers, pesticide registrants, and
pesticide formulators. It is absolutely essential that EPA allow
adequate time for industry to conduct a thorough analysis of the
potential impact of these policies and procedures so that the comments
adequately address the many complexities presented in the draft document
in a thoughtful and deliberative manner. For all of these reasons, CPDA
believes the requested extension is warranted.

CPDA appreciates the extensive time and effort EPA has invested in
developing these proposed policies and procedures and would like to
provide the Agency with meaningful comments to help expedite
implementation of the EDSP. As the Agency has grappled with many of the
issues raised in the draft EDSP document, so too must the inert and
pesticide industries expend significant time and effort to research,
analyze, and comment on the legal, regulatory, business, and other
implications the proposed policies and procedures present. Similarly,
the ICR raises many issues (including testing cost estimates) that will
require time to research and analyze. It will be necessary to undertake
extensive review, and concurrent discussions with testing facilities and
industry experts, to provide accurate and useful comments. Therefore,
CPDA requests 90-day extensions for each of these regulatory actions.

Thank you for considering our request and CPDA looks forward to
receiving a response from the Agency. If you have questions concerning
these requested extensions, please contact me at (202) 386-7407 or
mwhite@cpda.com.

> Sincerely,
>
> Michael C. White, Ph.D., J.D.
>
> Director of Regulatory Affairs