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: EPA–HQ–OPPT–2015-0078

Dear Dr. Barone: 

The American Chemistry Council (ACC), on behalf of its members and a number of allied trades1,

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 information 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 

EPA 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, meet 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 you 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 Specialty 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 have 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-

249-6406. 

Sincerely, 

Christina Franz 

Senior Director, Regulatory & Technical Affairs