TCE Public Workshop July 29

- 30, 2014 Comments by Christina Franz Senior Director, Regulatory & Technical Affairs American Chemistry Council

ACC member companies do not sell TCE into the use applications that were the focus of EPA’s TCE risk assessment. ACC members that manufacture TCE sell into large commercial markets where exposures are very well controlled. The fact that there are uses and applications of TCE where the exposures are well controlled was noted by Dr. Tala Henry yesterday and should be
reiterated. For these reasons , I was not inclined initially to provide any specific remarks during this workshop. However, after listening to the presentations and discussion over the last day

and

- a

- half, I would like to offer a few thoughts and observations.

First, it is important to note at the outset that ACC supports EPA’s effort to conduct targeted risk assessments on priority chemical s. This is important work that should continue in the existing chemicals program.

Supporting a model of continuous improvement, some refinements should be made in EPA’s overall approach to the assessments and we are collaborating with the agency and assi sting their efforts to identify effective and efficient ways to improve and refine the assessments, particularly as it relates to the exposure assessment component of the assessments. These efforts should help to identify if there is any actual risk posed . This is critical if the agency is going to rely on these risk assessments for regulatory decision making. No sector or stakeholder is well served by regulatory actions that do not actually mitigate real risks.

ACC also very much supports EPA’s opennes s and engagement with stakeholders in this workshop to solicit views and perspectives on risk reduction options that may address potential
concerns raised in its assessment.

Over the last

- day

- and

- a

- half, we have heard a significant number of presentatio ns about alternatives that can be substituted for TCE in various applications. However, risk reduction does not always mean that an alternative is the most effective or appropriate risk management measure. Alternative assessment is only one of many risk m anagement measures that can and should be considered. And, as was very apparent from the discussion yesterday and mentioned by Maria Doa in her remarks this morning , there is no one

- size

- fits

- all solution for every business or application. Consequently, the industry or industries that will be impacted by therisk reduction measures

– in this case, small degreasers

– should be fully engaged to ensure

that their businesses, processes, needs, and actual exposure scenarios are fully understood.

I urge EPA to work with the Small Business Administration (SBA) to survey small degreasers to answer the exposure questions the agency could not answer or may have over or
underestimated in its assessment.

In addition, should the exposures identified actually pose a risk that should be reduce d or mitigated, the SBA should be able to identify small degreasers to work with the agency to identify how those risks might be best managed or reduced. These steps are essential for EPA to ensure that future actions that may b e considered (be they educational, voluntary, or regulatory) are appropriate and will lead to meaningful risk reductions.

Thank you for the opportunity to comment.