# PAUONB066SLIP

ATTORNEYS AT LAW 

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2550 M Street, NW Washington, DC 20037-1350 202-457-6000

., Facsimile 202-457-6315 ~== www .pattonboggs.com :r-. 

### December 10, 2010 I V1--

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### BY HAND OPPT Document Control Office (DCO) EPAEast Building, Room6428 1201 Constitution Avenue, NW Washington, DC20004



### 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 briefextension of the comment period for this purpose. The purpose ofthis 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 EDSPTier 1 Screening to Identify Candidate Chemicals for Tier 2 Testing."2 Absent an extension, comments are dueJanuary 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 reviewand better understand how EPAplans 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) .



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CONTAINS NOCB!

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# PARONB0GGSuP

AiioRMErs Ar tAw 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) . Thefirst list of chemicals for which the Agency intends to issue test orders under EDSPwas directed at active and inert pesticide ingredients.3 The second list was issued in response to language in the HouseAppropriations Committee FY 2010 EPAAppropriations Report, directing EPAto "publish within one year of enactment a second list of no less than 100chemicals 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 ofthe 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 reviewof OSRI in the case of less toxic compounds that are not released into the environment for the purpose ofkilling competing organisms. More time is needed to develop this and related information. We request that EPAextend 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, 

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3 74 Fed. Reg. 17560(April 15, 2009) . 4 H .R . 2996, H

. Rept . 111-180

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W . Caff6y Norman

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