January 21 , 2014

Mr. Mark Seltzer

Chemical Control Division (7405M)

Office of Pollution Prevention and Toxics

Environmental Protection Agency East Building

1200 Pennsylvania Avenue NW Washington, DC 20460

– 0001 ( via e

- mail: seltzer.mark@epa.gov )

Re: Enforceable Consent Agreement Development for Two Cyclic Siloxanes (EPA Docket

Number: EPA

– HQ

– OPPT

– 2012

– 0209 )

Dear Mr. Seltzer :

The American Cleaning Institute (ACI) is pleased to provide the following comments on the

draft Enforceable Consent Agreement (ECA) for environmental testing for the cyclic s iloxane

octame thylcyclotetrasiloxane (D4) ( EPA Docket Number: EPA

– HQ

– OPPT

– 2012

– 0209 ) dated December 19, 2013

. ACI is an Interested Party to the development of the ECA.

We find the draft ECA has been prepared in a very thoughtful and rigorous manner. This was further evidenced by the previous public meetings held by EPA in developing the document. We believe the implementation of the ECA test plan will yield valuable data to characterize environmental exposures to D4.

The purpose of the testing program proscribed in the ECA is to collect data which will more

fu lly describe environmental exposure of aquatic and sediment dwelling organisms to D4. The context of the exposure assessment is the risk assessment of D4 as part of EPA’s assessment of

TSCA Work Plan chemicals which were announced on March 27, 2013. As p art of the March 28, 2013 meeting of the Siloxane Enforceable Consent Agreement Interested Parties and

Observers , EPA included in the meeting materials a draft of the outline and Chapter 1 of the Risk

Assessment Plan . This outline of the Risk Assessment P lan included the conceptual model for the environmental assessment of D4 including the agency’s thinking on how components of the report would be documented including physical chemistry, fate, releases, exposures, hazard assessment, risk characterization a nd uncertainties. In the intervening months (and possibly years) while the environmental exposure test data is being collected under the ECA , we believe it would be valuable for the agency to publicly release (to the docket) the information that it

intends to use in or der to characterize the physical chemistry, environmental fate and

environmental hazard s and solicit comments

. In addition, we believe it would be valuable forMr. Mark Seltzer Page 2 of 2

January 21

, 2014

the agency to further refine their conceptual model and approach, and make that information available to the public for comment

.

In addition, w e note that the agency is currently sponsoring the peer

- review panel for the

December 2012 HHCB environmental risk assessment. The agency has assembled a very knowledgeable and seasoned panel that through its first two meetings has provided critical analysis of that assessment and proposed some significant improvements. Likewise, a number of comments were provided to the agency by outside parties to improve their analysis and their Work Plan risk assessment process. We believe that a more interacti ve approach in developing the assessments, and greater transparency by the agency during the development of the Work Plan risk assessments would improve the quality of the product and result in a more efficient

process.

We appreciate EPA’s consideration o f our comments and look forward to working closely with the agency in the future on this matter.

Sincerely

,

Paul C. DeLeo, Ph.D. Senior Director, Environmental Safety