americanchemistry.com ® 700 Second St., NE | Washington, DC | 20002 | (202) 249

- 7000 May 7, 2015

Submitted Via Electronic Mail

Dr. Stanley Barone Risk Assessment Division (7403M)

Office of Pollution Prevention and Toxics Environmental Protection Agency

1200 Pennsylvania Ave., NW Washington, DC 20460

- 0001 barone.stan@epa.gov

Re: EPA TSCA Work Plan Problem Formulation and Initial Assessment of 1,4

- Dioxane; 80 Fed. Reg. 23545 (April 28, 2015); Docket ID: E PA

– HQ

– OPPT

– 2015

- 0078

Dear Dr. Barone:

The American Chemistry Council (ACC)

, on behalf of its members and a number of allied trades 1

, respectfully requests a 120

- day extension of the public comment period for EPA’s TSCA Work Plan
Problem Formulation and Initial Assessment of 1,4

- Dioxane (Problem Formulation).

ACC and its allied trade associations

, each of which has a significant interest in the risk assessment of 1,4

- dioxane, met with EPA on May 28, 2014, to discuss EPA’s initial questions regarding the potential exposures to this substance. Industry was asked to compile relevant occupational and consumer exposure information and submit it to EPA no later than June 16, 2014. We met that short deadline and provided a variety of relevant information and data, including occupational and consumer exposure informati on and a corrected 2012 Chemical Data Report (CDR).

Industry was informed in July 2014 that EPA upper management had concurred with the recommendation of the Risk Assessment Division (RAD) that the assessment be concluded at problem formulation and that

E PA would make public a document reflecting that conclusion in late summer/early fall 2014. Instead, nine months passed before the current Problem Formulation on 1,4

- dioxane was released and industry

was not re

- engaged to discuss what caused EPA to change course. The document released by EPA now identifies two areas of potential concern that may suggest an assessment is warranted. We believe the last nine months, unfortunately, represent a missed opportunity to discuss the Agency’s remaining questions

with stakeholders and allow us to collect and provide data and information that may well have responded to EPA’s exposure questions.

It is essential that sufficient time be allowed for stakeholders to review and evaluate the Problem Formulation document, m eet with EPA to understand its concerns, gather relevant information, and formulate comments. To that end, we request a meeting as soon as possible to discuss the Problem

Formulation document . We appreciate your attention to our requests and once again encourage y ou to extend the comment period for an additional 120

- days to allow for a thorough response.

1 Allied trades participating in this effort include the Adhesives and Sealants Council (ASC), American Cleaning Institute (ACI ), American Coatings Association (ACA), Consumer Specia lty Products Association (CSPA), Personal Care Products Council (PCPC). The Society of Chemical Manufacturers and Affiliates (SOCMA) and Waste Management, Inc. (WM) were not an original participant in the Work Plan pilot, but ha ve recently joined our alliance of interested trades on this Problem Formulation.2

americanchemistry.com ® 700 Second St., NE | Washington, DC 20002 | (202) 249.7000 Should you have any questions, please contact me at christina_franz@americanchemistry.com or 202

- 24 9

- 6406.

Sincerely,

Christina Franz Senior Director, Regulatory & Technical Affairs