January 23, 2015

Mr. Arnold E. Layne

Director

Office of Information Analysis and Access (Mail Code 2841T)

Office of Environmental Information

Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

CC: Daniel R. Bushman, Ph.D. 

TRI Petitions Coordinator 

Office of Information Analysis and Access (Mail Code 2842T) 

Office of Environmental Information 

Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460

Re: Transmittal of Petition to Delist EGBE from Certain Glycol Ethers Category on TRI

Dear Mr. Layne and Dr. Bushman:

On behalf of its Ethylene Glycol Ethers Panel, the American Chemistry Council (ACC) is pleased to 

submit the attached petition to the U.S. Environmental Protection Agency (EPA) to remove ethylene 

glycol monobutyl ether (EGBE) from the category Certain Glycol Ethers under the list of chemicals 

requiring reporting under the Toxics Release Inventory (TRI) pursuant to Sections 313(d) & (e) of the 

Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). 

As the attached petition demonstrates, available scientific data indicate that EGBE poses low potential 

hazards to human health and the environment, making an assessment of exposure appropriate under 

EPA’s policy for making TRI listing decisions under EPCRA. When EPA proposed to remove EGBE 

from the Clean Air Act’s list of Hazardous Air Pollutants (HAPs) in November 2003, it specifically 

determined, based on exposure assessments utilizing 1993 TRI data, that there is “reasonable 

assurance” that any potential adverse human health and environmental effects “will not occur” from 

EGBE facility releases (68 Fed. Reg. 65648, 65660 (Nov. 21, 2003). In the final rule, the Agency

concluded “with confidence” that releases of EGBE “may not reasonably be anticipated to cause any 

adverse effects to human health” or “adverse environmental effects” (69 Fed. Reg. 69320, 69322

(Nov. 29, 2004).
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There now is an even stronger basis for making essentially the same statutory findings under EPCRA 

and removing EGBE from the TRI reporting list. As shown in this petition, EGBE releases and 

exposures are now lower than those that formed the basis for EPA’s HAPs determinations. Delisting 

under EPCRA would remove a significant disincentive to the use of EGBE, a solvent that has proven 

to be highly effective in a variety of important water-based coating formulations with demonstrable 

volatile organic compound (VOC)-reduction benefits. For the reasons set forth in full in this petition, 

the EPCRA delisting criteria are satisfied and EPA should remove EGBE from the TRI reporting list.

As you know, EPCRA § 313(e)(1) provides that EPA will respond to a petition to add or delete a 

chemical from the TRI list within 180 days of receipt. In the meantime, ACC would welcome the 

opportunity to meet with you and the staff who will be responsible for evaluating the petition, in order 

to discuss methods and findings and to answer any questions. To arrange such a meeting, please 

contact me at your convenience at (202 249-6725; jon_busch@americanchemistry.com.

Sincerely,

Jonathon T. Busch

Manager, Ethylene Glycol Ethers Panel

Director, Chemical Products & Technology Division