PAUON B066SLIP 

ATTORNEYS AT LAW 

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2550 M Street, NW 

Washington, DC 20037-1350 

202-457-6000 

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Facsimile 202-457-6315 ~== 

www.pattonboggs .com :r-. 

December 10, 2010 

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BY HAND 

OPPT Document Control Office (DCO) 

EPA East Building, Room 6428 

1201 Constitution Avenue, NW 

Washington, DC 20004 

Re: EPA-HQ-OPPT-2010-0877 

Dear Sirs : 

The Halogenated Solvents Industry Alliance, Inc. (HSIA) represents manufacturers of 

trichloroethylene, perchloroethylene, and methylene chloride, three of the 134 chemicals on 

the second list of chemicals for which EPA intends to issue test orders under the Endocrine 

Disruptor Screening Program (EDSP) .' In addition to these chlorinated solvents, HSIA 

member companies manufacture a number of other listed chemicals . HSIA intends to 

comment on the appropriateness of inclusion of a number of these compounds, and 

appreciates EPA's willingness to grant a brief extension of the comment period for this 

purpose. 

The purpose of this letter is to seek an extension of the deadline for comments on a 

closely related notice of availability of a draft document entitled "Weight-of-Evidence 

Guidance Document: Evaluating Results of EDSP Tier 1 Screening to Identify Candidate 

Chemicals for Tier 2 Testing."2 Absent an extension, comments are due January 3, 2011 . 

Manufacturers of compounds on the second list, however, had no reason to be aware of the 

availability of the guidance document until publication of the second list on November 17, 

two weeks into the 60-day comment period . For the reasons described below, these 

manufacturers require additional time to review and better understand how EPA plans to 

evaluate Tier 1 screening data to determine if Tier 2 testing is required in the context of the 

compounds they manufacture, and to provide meaningful comment to EPA. 

t 75 Fed. Reg. 70248 (Nov. 17, 2010). 

2 75 Fed. Reg. 67963 (Nov. 4, 2010). 

00-'l =2o 1 () -0877 

CONTAINS NO CB! 

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A iioRMErs A r t A w 

OPPT Document Control Office (DCO) 

December 10, 2010 

Page 2 

EDSP is the current iteration of an effort begun in 1998 to screen pesticides for 

endocrine effects, as required by the 1996 Amendments (the Food Quality Protection Act) to 

the Federal Food, Drug, and Cosmetic Act (FFDCA). The first list of chemicals for which 

the Agency intends to issue test orders under EDSP was directed at active and inert pesticide 

ingredients. 3 The second list was issued in response to language in the House Appropriations 

Committee FY 2010 EPA Appropriations Report, directing EPA to "publish within one year 

of enactment a second list of no less than 100 chemicals for screening that includes drinking 

water contaminants, such as halogenated organic chemicals . . . and issue 25 orders per year 

for the testing of those chemicals ."4 

As in the case of the second list, more time is needed to identify different 

manufacturers, contact them, and make arrangements for costs. At least in the case of the 

chlorinated solvents, mammalian reproductive toxicity studies are available that would 

appear to meet the most significant Tier 2 testing requirement . It is therefore important that 

HSIA understand, for example, EPA's position on other scientifically relevant information 

(OSRI) as described in the draft guidance and as developed in the context of pesticides on the 

first list. There may be other considerations that affect the review of OSRI in the case of less 

toxic compounds that are not released into the environment for the purpose of killing 

competing organisms . More time is needed to develop this and related information . 

We request that EPA extend the comment period for 45 days in order to give 

interested parties adequate time to respond. ' 

Please do not hesitate to contact me if there is any question about this request. 

Sincerely, 

C 

3 74 Fed. Reg. 17560 (April 15, 2009). 

4 H.R. 2996, H. Rept. 111-180. 

G J ~ v,/ ~- 

W. Caff6y Norman 

5136379