U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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EPA 

Moderator: John Shoaff 

September 7, 2011 

1:30 p.m. ET

Operator: Good afternoon. My name is Tameka, and I will be your conference operator 

today. At this time I would like to welcome everyone to the Identifying 

Priority Chemicals for Review and Assessment Conference Call. 

 All lines have been placed on mute to prevent any background noise. After 

the speaker’s remarks, there will be a comment session. If you would like to 

make a comment during this time, simply press star then the number one on 

your telephone keypad. If you would like to withdraw your comment, press 

the pound key. Thank you. 

 Mr. John Shoaff, you may begin your conference. 

John Shoaff: Thank you very much. Welcome to EPA’s webinar and audio teleconference 

on Identifying Priority Chemicals for Review and Assessment. I’m John 

Shoaff with EPA’s Office of Pollution Prevention and Toxics. 

As you saw with the reminder to the webinar, the agenda is as follows: we’ll 

begin roughly 1:30 to 2:00 by presenting an overview of the discussion guide 

on the Two-Step Prioritization Process that has also been circulated and 

posted;. From 2:00 to 3:20, we’ll take input on questions on Step 1. From 

3:20 to 3:30, we’ll take a short break, and from 3:30-4:30, we’ll take questions 

on Step 2, input with questions on Step 2, excuse me. 

 Comments will be taken in the order received. Please note that if we’re 

unable to address all comments for an agenda item during the time allocated, 

we may need to clear and restart the comment queue to move on to the next 

agenda item. So, you know, alternatively, we may also truncate the schedule 

with the agenda if we have enough time and depending on the number of 

comments with each item. 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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 Please try to limit your comments to roughly three minutes in the interest of 

providing time for others to provide input. We have a very large audience in 

participation today. So thank you for that. 

 And if you need assistance at any time, please press star 0 for the Operator. 

And if there’s not enough time for everyone to provide comments or later 

during the webinar, comments can also be provided electronically. Although, 

if provided to the webinar, they will not be viewable in real time, but we will 

have them and be able to answer them in the docket. 

 And I’d also highlight that comments can also be posted to our discussion 

blog through close of business 5:00 pm on September 14. After the forum 

closes, EPA will place the entire discussion forum with comments included to 

the associated docket. With that, I will turn it over to Wendy ClelandHamnett, our Director of the Office of Pollution Prevention and Toxics. 

Wendy Cleland-Hamnett: OK, thank you, John. Thanks, everyone, on the phone for taking 

the time to listen to this presentation and provide us with comments this 

afternoon. Your input is greatly appreciated, and we’re looking forward to 

hearing it. 

 I’ll go ahead and start the presentation. We’ll go to Slide 2. This is – Slide 2 

is just to make the point that shortly after becoming the EPA Administrator, 

Lisa Jackson made it clear that improving our chemical management program 

here at EPA was one of her top priorities. And that included advocating for 

reform of the Toxic Substances Control Act, which is the authority under 

which we carry out our existing chemicals program here in the Office of 

Pollution Prevention and Toxics. 

 The Administrator stressed she was very much interested that while we 

worked on reform of TSCA, that we also used the authorities that we have 

under our current statute to the best of our ability to make sure that we’re 

doing what the American public expects in terms of gathering data on 

chemicals, reviewing that data and taking action where it’s warranted. 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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 So we’ll move to the next slide. I want to make sure that there’s an 

understanding that the exercise that we’re talking about here today, which is 

identifying the highest priority chemicals for us to review, assess and 

potentially take action on, is part of a larger context that our ongoing existing 

chemicals program in my office, Pollution Prevention and Toxics, that we 

carry out under TSCA. 

 So as part of that larger ongoing program, we have activities to gather 

information that help us to better understand what’s going on in the chemical 

industry and with chemical risks. And that includes using test rules to require 

the testing of chemicals. We’re in the process of completing the issuance of 

test rules on high production volume chemicals that were part of the High 

Production Volume Challenge Program that we undertook a number of years 

ago. 

 We are also looking, as we complete that phase of the testing program, in our 

HPV-4 proposed rule. It should be coming out shortly. We’ll be soliciting 

comment on future direction of that program in terms of how we best identify 

chemicals that might be subject to testing requirements, as well as taking a 

look at whether the screening information data set, which is the battery of tests 

that we’ve been using in the HPV program, continues to be the best set of 

testing for chemicals or whether we want to look at alternative testings. We 

continue to review the data that we’ve received under the HPV Challenge and 

other aspects of the program and to post hazard characterizations for 

chemicals. We’ve been doing that for a number of years. We’ll continue to 

do that. 

 We’ve recently published amendments to our Chemical Data Reporting Rule, 

and we’ll be getting a new round of reporting information on production 

volume, uses and other information on chemicals next year. So we are – 

while we’re getting ready for the submission of that data, we are also looking 

at how best to make that data available to the public in ways that would both 

be useful, as well as how we will use it internally to improve our chemicals 

program. 
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 We continue to work on making more health and safety data that are part of 

our TSCA holdings here at EPA, making that data more accessible to the 

public and with a particular focus on health and safety and linking that 

information to chemical ID. So we continue to work on that area. 

 The agency had an initial set of priority chemicals that Lisa Jackson 

announced just about two years ago now in 2009, and we issued action plans 

for those 10 chemicals or categories of chemicals. We continue to implement 

the actions that were identified in those plans. So we’ll be continuing to work 

on that. While as part of the program we’ll be identifying the next set of 

priority chemicals that we’ll begin to work on. 

 We’re working on some other rules to gather information on nanomaterials 

that will allow us to better understand what’s happening in the industry with 

nanomaterials and what potential uses and exposures are for those. We’re 

working on some risk management regulations for some other high priority 

chemicals, lead and mercury, under Section 6 of TSCA. 

 So all of that is to say that what we’re talking about today is very important in 

terms of identifying chemicals, which should be the highest priority for us to 

do some in-depth assessment and take action on, but to say that there is a lot 

of other work going on in terms of understanding the broader context and the 

broader array of chemicals that are in commerce and subject to TSCA. 

 So moving to Slide 4, the goal of what we are talking about today is to 

identify the highest priority chemicals, to determine whether risk is significant 

and whether risk management or other action under TSCA is warranted. 

 And what we’re focusing on in our discussion guide and looking for your 

comment on is that we’re talking about chemicals for this set of high priority 

chemicals, chemicals or data are (available) on hazard and where there’s an 

indication that a chemical or certain uses of those chemicals might present a 

significant risk, that there is significant exposure. 

 That allows us to take advantage of work that’s already being done by EPA, 

by other governments, whether they’re international or they’re state 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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governments, and allows us to move quickly to take action on these 

chemicals. 

 One important difference between some approaches to prioritization that have 

been taken in the past or that have been proposed is that we’re looking to 

quickly identify some of the highest priority chemicals that we can begin 

working on, while we continue to work on better understanding the broader 

array of chemicals. So we’re not looking at running, you know, a large 

number of chemicals, thousands of chemicals, through a screening process 

where we’d identify everything from very low concern chemicals to very high 

concern chemicals. These exercises focus more on trying to identify that next 

set of high priority chemicals that we should be working on. 

 Our plan is to have that set of high priority chemicals identified by late fall, 

for work in 2012 and possibly beyond 2012, depending on the number of 

chemicals that we identify through this process. Some people have asked 

whether we have a target number; we don’t. We’re trying to identify 

chemicals that you, our stakeholders, and we believe are the most important 

for us to be addressing. 

 And then depending on the number of chemicals we come up with, we will 

work through those over time. And we anticipate that this would be a rolling 

process. We’d work on the highest priority chemicals first, and when we were 

finished with those, we’d move on to another category of priority chemicals. 

 So when we release our next set of priority chemicals later this fall, we would 

intend to, at that point, talk about the factors that we used to identify those 

particular chemicals, and some idea of the scope of review that we would be 

intending to carry out for those chemicals. 

 Following that at a later date, we would provide information on the data that 

we would intend to use to review and assess those chemicals and provide a 

time period where interested parties could provide us with additional 

information that we did not have in our possession at that time, if they are 

private information holdings or things that we just missed in doing our review 

so that we have that information before we move into a more in-depth review. 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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 OK, next slide. So quickly, what we’re talking about here is the two-step 

process, and I essentially think of it as that Step 1 is a coarser step where 

we’re trying to cast the net and identify larger group of chemicals that could 

potentially become priority chemicals, and Step 2 would allow us to take a 

little bit closer look at those and help us to prioritize within the chemicals that 

are identified in the Step 1 screen those that we might want to take on sooner, 

those that we might want to take on later. That’s essentially the idea between 

the two steps. 

 So at this point, I think before we go into detailed comments on Step 1 factors 

and data sources, I’ll pause and, Tameka, open it up if there are folks on the 

lines who would like to make general comments on what we’ve presented so 

far in terms of the overview or what they’ve read in the discussion guide. 

We’ll do that and then we’ll move to the Step 1 factors - prioritization factors 

- part of the discussion. 

Operator: At this time I would like to remind everyone in order to make a comment, 

please press star, then the number 1 on your telephone keypad. 

 Your first comment comes from the line of Lin Kaatz Chary, with Great Lakes 

Green Chemistry Network. 

Lin Kaatz Chary: Great Lakes Green Chemistry Network. Thank you. 

 This is very encouraging and very interesting. The one thing that I’m not 

seeing and perhaps it’s going to be covered later, so I apologize if I’m 

jumping the gun, is that when you talk about Step 2, select chemicals for 

review and assessment including possible risk management action, are you 

looking – will this include also a push for alternatives and alternatives 

assessments? 

 I noticed that’s something that the Design for the Environment does, but I’m 

sort of wondering what the interaction is and where the efforts of Green 

Chemistry will fit into this entire framework that you’ve presented? Thanks. 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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Wendy Cleland-Hamnett: I’ll try to answer quickly to allow other people to comment, but 

alternatives assessment and Green Chemistry are some of the tools we’d bring 

to this, so it’s really regulatory actions and other actions. The ten Action 

Plans that we’ve issued over the last couple of years, a number of them 

include alternatives assessments for some of the chemicals covered in the 

Action Plans, for Green Chemistry challenges, so we expect to continue to 

look at that as one of the potential tools that we’d use. 

Operator: Your next comment comes from the line of Michael Buczynski with Church 

& Dwight, Inc. 

Michael Buczynski: Yes, will you have slides after the conference call for those of us who 

cannot access the Go To Meeting? 

Wendy Cleland-Hamnett: Yes. We’ll post the slides to our website. 

Michael Buczynski: OK, thank you. 

Wendy Cleland-Hamnett: You’re welcome. 

Operator: Your next comment comes from the line of Barbara Warren with Citizens’ 

Environmental Coalition. 

Barbara Warren: Yes, thank you very much. I’d like to mention one thing that appears missing 

from the Step 1, and that would be how much of the chemical is produced or 

used? That does not appear to occur until the second step. And then the other 

question is, the biomonitoring seems to be just geared to human biomonitoring 

not environmental sources of data, say the USGS or other, you know, drinking 

water or that type of a source, and so I wanted to raise that question. In other 

words, prevalence in the environment. 

Wendy Cleland-Hamnett: Thank you. 

Operator: Your next comment comes from the line of James Conrad with Conrad Law 

and Policy Counsel. 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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Jamie Conrad: Hi, Jamie Conrad. I guess I had a clarifying question and a comment. The set 

of chemicals that you would release in late fall with an invitation for people to 

supply more data, is that considered Step 1? 

Wendy Cleland-Hamnett: That would include through Step 2. 

Jamie Conrad: So by the time it would come out in the fall, that you would have – that would 

be Step 2. OK. 

 My comment is, is this. There’s a lot of criticism of the TSCA program that 

there are 80,000 chemicals on the Inventory, I’m clarifying, I’m just speaking 

for myself. And one would think, in light of that, that one approach you might 

do is to try, as quickly as possible, to whittle that down to the ones worth 

being concerned about, which is what Canada did, and they took their 23,000 

chemicals on their Domestic Substances List, and over six years, they whittled 

that down to a set that they wanted to keep working on. You would think 

EPA, between an Inventory reset and some sort of screening effort like what 

Canada did, you could take tens of thousands of chemicals off the list and 

show some progress, whereas, it seems to me what you’re proposing now is 

essentially to keep biting off 10 here and 10 there with another 80,000 sort of 

looming out there really forever, and I just wonder if that really addresses the 

kinds of concerns people have identified. 

Wendy Cleland-Hamnett: OK, thank you. 

Operator: And there are no further comments. 

Wendy Cleland-Hamnett: OK. So with that, we’ll move to Slide 6. Here, we were looking at 

getting comments on the prioritization factors that are in the discussion guide, 

oh I’m sorry Slide 7 – OK, they’re number 6, yes. Sorry folks, numbers are 

different than what I have in my presentation here. 

 So Step 1 questions. We’re looking to get input on the chemicals that, sorry, 

the factors that we would use to select priority chemicals. We have six factors 

listed. Some of them relate more to the hazard side, some of them relate more 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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to the exposure side, some of them such as PBTs are probably a combination 

of those. 

 But what we are looking for as you make your comments, looking for you to 

keep in mind, is whether you’d support the use of these factors and why that 

is, if you believe that a given factor is not appropriate and why you would 

believe that to be the case. You might have comments specifically on how we 

approach a factor, or there might be prioritization factors that you believe that 

EPA should consider that we don’t have on this list. So I’d ask you to address 

these questions as you provide comments to us in this part of the discussion. 

 So do we have any comments in this area? 

Operator: Again if you would like to make a comment, please press star 1. And your 

question comes from the line of Georjean Adams with EHS Strategies. 

Georjean Adams: This is Georjean. It wasn’t clear to me that you were going to be looking at 

both exposure and toxicity together. It seems to me that if you’re going to be 

focusing on the worst first, that you’d want to look at those chemicals that had 

both high exposure potential and high toxicity. And it almost looks like from 

the way you’ve listed this, and I think I read it somewhere, that one or more, 

and I guess, I would recommend that it be many of the characteristics so that 

you were indeed looking at the highest risk. 

Wendy Cleland-Hamnett: OK, thank you. 

Operator: Your next comment comes from the line of Mark Mitchell with the National 

Medical[Association]. 

Mark Mitchell: Yes, this is Mark Mitchell. I have a couple of comments. First of all I 

disagree with the last speaker. I think that if you’re casting a wide net, then 

any one of the criteria should be enough to get the chemicals into that wide 

net. 

 My comment is that, historically, EPA and science as a whole has not been 

very good at predicting exposures. And this is particularly true in 

environmental justice communities, where part of the definition of 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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environmental justice communities, those low income and communities of 

color, is an unusual exposure pathway, as well as disproportionate exposure, 

as well as increased susceptibility. 

 And examples of chemicals that were thought to not have wide exposure are 

things like PCBs and, you know, which were, of course, outlawed in the 

original TSCA, as well as some TCE, which is supposed to be a industrial 

chemical but a lot of environmental justice communities are being exposed to 

them through brownfields, as well as some chromium-6. And these are also 

not the PBTs, they’re not persistent, bioaccumulative, and toxic. 

 So given the premise that exposure is not very well predicted, I would propose 

two things. One is that you look at production volume as a potential indicator 

of exposure in addition to the biomonitoring and PBT characteristics. But 

also, that you currently look at what’s poisoning people now. You know, 

there are a number of chemicals that are out there, again, that people are 

currently suffering the consequences of, you know, lead poisoning, mercury, 

just a number of chemicals. And so I propose that, that also be a criteria, 

those toxics that people are currently being exposed to. 

Operator: Your next comment comes from the line of Carol Kwiatkowski, of TEDX. 

Carol Kwiatkowski: Hi., I just wanted to comment that I think that another factor you should 

consider is chemicals identified as endocrine disruptors. Thank you. 

Wendy Cleland-Hamnett: Thank you. 

Operator: Your next comment comes from the line of Melanie Marty with California 

EPA. 

Melanie Marty: Hi, I just wanted to add in that in addition to biomonitoring programs, since 

the list of chemicals for which we have found biomonitoring information for 

is quite limited, that you do have to look at environmental media. So, there 

are a number of data sources including from the State of California and other 

states that could indicate widespread exposures. So you have to expand your 

horizon on the exposure end of things. And also I liked what the last person 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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said about endocrine disruptors and neurotoxic chemicals as well, which, 

generally, are shown to be worse in the developing organisms. Thank you. 

Wendy Cleland-Hamnett: Thank you. 

Operator: Your next comment comes from the line of Mark Rossi with Clean 

Production. 

Mark Rossi: Hello, I was just going to remove my comments because I was just going to 

agree with the – I was going to make the point around adding neurotoxicants 

and so I agree with that point, and I also agree with the point on adding 

endocrine disruptors. And I would also say that just reproductive and 

developmental effects are also important to women of child-bearing age. So 

we wouldn’t want to just limit chemicals at a repro-developmental toxicants 

of concern to children’s health, but it would also be for women of 

reproductive age. Thank you. 

Operator: Your next comment comes from the line of Jennifer Canvasser with The 

Michigan Network for Children’s Environmental Health. 

Jennifer Canvasser: Hi, I just wanted to recommend that in terms of prioritization and 

exposure factors that chemicals which cross the placenta barrier or blood brain 

barrier be included. 

Operator: Your next comment comes from the line of Betsy Duncan with 

LyondellBassel. 

Betsy Duncan: Hello, this is Betsy Duncan with LyondellBassel. Just a comment on the 

information pertaining to production volume as it would be a factor in 

potential exposure as one of your prioritization factors, I don’t see that in your 

Step 1, at all, and that’s it. Thank you. 

Operator: Your next comment comes from the line of Leonard Sweet with Labrazel. 

Leonard Sweet: Yeah, my comment is, is chemicals identified by whom? There are various 

lists and agencies and organizations that like to call things, for example PBTs. 

So my question is, identified by whom, carcinogens, IARC, NTP or OSHA or 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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others. I think that’s a critical part that’s missing is who’s the voice of 

authority and opinion here in terms of identifying all these labels and concerns 

on chemicals. Thank you. 

Wendy Cleland-Hamnett: Just a clarifying point on that. The next step of the process in the 

discussion guide that we posted online, we have a table of data sources that 

we would use to inform these factors. So for example, you know, IRIS 

determinations, IARC determinations and NTP findings, etc., listed in those 

tables, and we’ll actually be asking for comments on those on the next part of 

the discussion here. 

Operator: Your next comment comes from the line of Alex Stone with Washington State 

Department [of Ecology]. 

Alex Stone: Yes, hello, thank you. Just one comment and then one sort of observation, if 

you will. You did mention that you’re going to be working with states, and the 

states are formulating written comments and will probably submit them at 

some point further on, so we’ll be providing more detail. But I do want to 

emphasize is that it’s important to work with the states that have already done 

a lot of this process already, so you could learn from what we have done and 

build upon that. But second of all, the sort of general comment is that I don’t 

object to your prioritization, what you’re selecting as the prioritization criteria 

here in Step 1 questions, but what you need to do is to cast a very broad 

network of criteria to identify the chemicals of concern. 

 So I agree with a lot of the comments that have been made earlier, 

particularly, including your broad network of chemicals that impact not just 

humans but the environment. And then when you have that large universe, 

you use those chemicals, those prioritization steps that you have here to 

narrow focus down on the ones that are most important in the short term. 

 But, you know, I’m looking at this from the broader perspective as well, as is 

that it would be good for EPA to use its resources and identify this larger 

universe of chemicals, so that those of us who are trying to do alternative 

assessments and selecting safer alternatives will have more information 
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available to us on what chemicals are and are not viable alternatives to toxic 

chemicals. Thank you. 

Operator: Your next comment comes from the line of Marjorie Martz-Emerson with 

Hewlett Packard. 

Marjorie Martz-Emerson: Thank you. I just wanted to add maybe another vote to the 

comment on neurotoxins. I think in this country we are having an epidemic of 

neurological diseases, and I think it is very important that we not look at just, 

you know, some of the more familiar ones of carcinogens and reproductive 

toxins, that we include neurotoxins in your list. 

Operator: Your next comment comes from the line of Liz Harriman with TURI [Toxics 

Use Reduction Institute]. 

Liz Harriman: Hi, this is Liz Harriman from the Toxics Use Reduction Institute. I’m 

interested to know how relatively new substances like nanomaterials might be 

considered in these criteria. Little concerned that they may drop through the 

cracks between the existing and new chemicals programs where there isn’t 

enough firm information about their hazard. They’re very difficult to detect 

period, and yet they’re not being evaluated before they become commercially 

produced. 

Operator: Your next comment comes from the line of Derek Swick with API. 

Derek Swick: Good afternoon. I wanted to agree with EPA not including production 

volume as a prioritization factor and certainly API would not support using 

volume itself as a surrogate for exposure. Here, it’s important that any 

approach for prioritization be based on true exposure rather than an incorrect 

assumption that volume is highly correlated with exposure. I also want to 

recommend existing regulatory controls as a possible prioritization factor as 

well, adding to what’s currently on the slide. Here chemicals or mixtures for 

which risks are already managed under existing regulatory schemes should 

have a relatively low priority in a prioritization scheme. 
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 Finally, the net that EPA is casting needs to include both hazard and exposure 

factors for prioritization. It’s important that any prioritization of a chemical 

be based on, at least, one hazard factor and one exposure factor, not a single 

factor. Here, there’s essentially no risk if there’s no exposure or no hazard, 

and EPA’s approach to this, based on the discussion document, appears 

unclear. 

Operator: Your next comment comes from the line of James Cooper with the National 

Petrochemical & Refiners Association. 

James Cooper: Good afternoon, everybody, and nicely done on the title of the organization. 

That’s perfect, thank you. 

 My main comment is I think there’s going to be a great deal of 

communication that needs to be done because the Step 1 in the priority setting 

process is more of a regulatory step. It really isn’t a risk assessment per se. 

And the more factors you add in to Step 1, the more bogged down this process 

is going to be and the slower it’s going to be. 

And I think we all need to keep in mind that this is probably going to end up 

being a multi-layered process, where you have an initial step just to prioritize 

where you want a study and possibly even do or conduct risk assessments. 

You may get some output from Step 1 that says, we need data for some of 

these chemicals, and so that would result, possibly, in either a section 4 test 

rule or a PAIR rule to collect exposure information. So I think if, you know, 

if EPA takes its time to really communicate each step of the process and the 

expectations of the outputs of those steps, I think a lot of the stakeholders will 

realize that as you go through these layers, a lot of these considerations that 

are being brought up will be considered. 

 It just may not be in the initial cut because if you get, you know, 6- 7,000 

chemicals after the initial cut, you really just wasted a step because all you 

have to do is look at the IUR to get that number of chemicals. 

 And so, there does have to be some kind of consideration and, obviously, you 

know, we’re very supportive of considering both hazard and exposure even in 
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Step 1 because that way you’re not going to waste resources chasing 

something that doesn’t actually present harm. Thank you. 

Operator: Your next comment comes from the line of Scott Braithwaite with Clorox. 

Scott Braithwaite: Hi, I’d like to echo the same concern over the number of chemicals coming 

out of Step 1. I heard earlier in the call that thousands of chemicals is not an 

ideal outcome of Step 1. I was wondering if it’s more like a couple of 

hundred chemicals that you hope to identify in Step 1. 

Wendy Cleland-Hamnett: I think that would be more in the ballpark of what we expect, yes. 

Operator: Your next comment comes from the line of Carol Kwiatkowski, with TEDX. 

Carol Kwiatkowski: Thank you. I wanted to add on to the comments that have emphasized 

production volume as an important factor and say that from our research,.if 

you do consider production volume, I think it’s really important that you 

consider global production volume and not just in the U.S. Thank you. 

Operator: Your next comment comes from the line of Nelson Lawson with Pine 

Chemicals Association. 

Nelson Lawson: Good afternoon. I want to deal with this question of the data sources that the 

Agency intends to use, which is the slide up on the screen now, and to caution 

EPA about the chemical lists that come out of Canada, which were picked by 

computer data models, some of which were not really good. 

 We know from experience in responding to Environment Canada that a 

number of chemicals of interest to us were simply misclassified by the 

computer models, and once we sent in the proper data to Environment 

Canada, they were all deemed to be chemicals of very little concern. So I 

would just suggest that EPA uses its own models and its own data from the 

HPV program and from others rather than relying on data outside, specifically 

from Canada. Thank you very much. 

Operator: And there are no further comments. 
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Wendy Cleland-Hamnett: OK. We’ll then move on to the questions about the data sources 

that we would use to identify chemicals. We can put up slides that we have in 

the PowerPoint that summarize the data sources. There was also in the 

discussion guide that was provided on the website some more lengthy tables 

with a little more detailed information on the data sources, so if you have that 

accessible to you, you might want to look at that. 

 But we’re interested, again, and, you know, whether you think these data 

sources are appropriate and why. If you think some of them are not 

appropriate and why that would be the case. Are there additional data sources 

that you think the agency should be looking at and if you’ve, particularly, if 

you’ve proposed additional factors for prioritizing, if there are particular data 

sources you have in mind to help inform these factors that would be useful as 

well. So, we’ll take comments on the Step 1 data sources at this point. 

Operator: Again to make a comment, please press star 1. Your next comment comes 

from the line of Nohemi Zerbi with Department of Home [Department of 

Homeland Security]. 

Nohemi Zerbi: Good afternoon. Department of Homeland Security, this is Nohemi Zerbi. I 

just wanted to alert EPA about the Department of Homeland Security Science 

and Technology Directorate within the Chemicals Sector Analysis Center has 

been working for a number of years on toxicity, (inaudible) of certain list of 

chemicals and has actually prioritized these chemicals based on their toxicity. 

 This information is on classified piece, but it can be shared with EPA. I think 

some EPA members have been working with DHS on this for a number of 

years, and we just wanted to ascertain that we’re available to share that 

information with EPA. And I don’t see us there as a source of information for 

you guys. 

Wendy Cleland-Hamnett: Thank you. We’ll be interested in following up with you. 

Nohemi Zerbi: Thank you. 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

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Operator: Your next comment comes from the line of Nancy Peresco with the Dow 

Chemical Company. 

Nancy Peresco: Hi, I would be wondering if you needed to page down a slide. You say Table 

1 below, I don’t see Table 1. Thank you. 

Wendy Cleland-Hamnett: You’re welcome. 

Operator: Your next comment comes from the line of Michael Belliveau with EHSC. 

Michael Belliveau: Yes, thank you. This is Mike Belliveau with the Environmental Health 

Strategy Center. I had a little trouble accessing the slides so pardon me if I 

like back up a little bit in what I want to comment on. First, I think, EPA is 

exactly on the right track in using its existing authority, which is limited, to 

review, identify and review priority chemicals. 

 I think the type of comprehensive approach that was suggested by earlier 

commenter is the reason that we need TSCA reform and this is going to have 

to await TSCA reform before we can, we can hope to accomplish that. 

 Regarding the fact – this exercise is positive as it is. It’s challenging because 

of the serous limitations to the availability of health and safety data, and for 

that reason I think it’s important that the agency allowed itself to consider, as 

a priority, a chemical for which there is very good hazard data or very good 

exposure data, assuming that for the other parameter, it ranks high for the time 

being until those data gaps are filled. 

 I think there’s such a serious lack of available information that we need to 

have a way of prioritizing chemicals that we know something about but that 

we don’t enough about. So I would argue that either high hazard or high 

exposure alone should be one basis for listing a chemical as a priority. 

 And then my final comment is that I’m still – maybe it’s just because I’m 

back from vacation - I’m still soaking in the discussion guides proposal. But 

I’m a little confused about how Step 1 and Step 2 interact with each other. 

Wendy, you described Step 1 as a coarse sieve, but I think it should be 
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conceived of as casting a broad net. The way it’s constructed now seems a 

little backward. 

 It seems like you take a narrow set of data in which to identify potential 

priority chemicals in Step 1, and then do you use a broader set of data sets in 

Step 2? Shouldn’t it be the other around? Shouldn’t we cast a broad net 

rather than a coarse sieve, identify lots of potential priority chemicals and then 

narrow down the universe. Right now, I can’t really tell how Step 2 clearly 

falls from Step 1. 

Maria Doa: Hi, this is Maria Doa at EPA. I just wanted to clarify a little bit and thanks for 

that question, that’s a good question. The - Step 1 is taking chemicals that we 

think should be focused on because they’re in children’s products and 

consumers’ products; because they’re PBTs; they’ve been identified of 

concern for children’s carcinogens. 

 And so we’re looking at each of these independently as the source of 

chemicals to focus on. And then we’re going to take – and some of these, as 

Wendy said earlier, are hazards, some of them are high priority for exposure, 

some of them cover both like PBTs. 

 We would then take that list and then apply, and then do prioritization 

screening in Step 2, where we would be looking at chemical release data, use 

data, exposure data, hazard data for the things that we just have exposure on. 

And using the Step 2 is how we would prioritize among those chemicals. 

And, you know, we would be looking across those factors, you know, for the 

high, medium and low prioritizations. 

Operator: Your next comment comes from the line of Carol Kwiatkowski with TEDX. 

Carol Kwiatkowski: Hi, this Carol Kwiatkowski with the Endocrine Disruption Exchange. I 

wanted to mention three other potential data sources you might consider. One 

of them is your own Endocrine Disrupters Screening Program, which I think 

would be very important to see the data coming out of that. 
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 Another is a Swedish nonprofit, ChemSec, with its “Substitute It Now!” List, 

has come out with a list of 22 chemicals that are not necessarily showing up as 

carcinogens or reproductive or development, or having developmental effects, 

and yet there’s clear evidence of endocrine-disrupting properties and so that’s 

an important source of information that’s being proposed to the REACH 

program in Europe right now. 

 And then, of course, the NIEHS is doing a lot of research on the endocrine 

disruptors and looking at chemicals that may, have been on people’s radar 

screens for a while and unique mechanisms of action. And I think it’s 

important to look at those as well. Thank you. 

Operator: Your next comment comes from the line of Mark Rossi with the Clean 

Production [Action]. 

Mark Rossi: Hello, this is Mark Rossi, Clean Production Action. I was curious why you 

didn’t have reference to any of the European lists for which there’s been, you 

know, quite a lot of work done. There’s the European Substances Information 

System, European – these are all EU dangerous substances directives 

chemicals, CLP - Classification Labeling and Packaging - and also the EU 

substances of very high concern. 

 I mean I think it’s also – even though it’s a set of criteria rather than list, but 

to reference the Globally Harmonized System for the classification and 

labeling of chemicals, using the GHS criteria, because then that’s moving 

towards a set of international standards versus just each country doing its own 

thing. Thank you. 

Operator: Your next comment comes from the line of Charles Franklin with Akin 

Gump. 

Charles Franklin: Hi, Charles Franklin, Akin Gump. I have something – if I could just clarify 

one thing that I thought I heard. Looking at the list of the factors - you’ve got 

the specific hazard factors that are laid out - carcinogens, PBTs, reproductive, 

etc. - and then the three exposure factors to children’s products, consumer 

products, biomonitoring. 
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 I had in my notes, and I think it was maybe from one of the earlier slides, a 

reference to chemicals meeting at least one hazard and one exposure factor 

would become part of the initial group of priority chemicals for review. Is 

that – did I get that correctly because that seems to suggest that there really 

was a melding of the exposure and hazard? 

 And I guess, more generally, to the extent that that’s not correct, and if really 

just purely exposure use is a measure, I’d be interested in - if there’s been 

discussion about what being on this list as a starting point means for 

chemicals in terms of qualifying for, you know, DfE or the Green Chemistry 

programs. I mean is it recognized that this is just a list, this is not an actual 

initial set of problematic chemicals. 

Wendy Cleland-Hamnett: This is Wendy. We’ll just say that Step 1 is just that. It’s Step 1 

and as we said earlier, the priorities that we’ll be identifying for work in the 

program will have gone through Step 1 and Step 2. So, you know, as one of 

the earlier speakers said, Step 1 is the broader net and then we’ll be, you 

know, refining that and prioritizing within that. 

 The priority chemicals we identify will be based on risk so, you know, if 

there’s a chemical identified that has high hazard but we can’t identify 

significant exposure, it’s not likely to end up being a priority chemical or vice 

versa - you might have significant exposure, but if there’s no evidence of 

hazard, it wouldn’t end up as a priority chemical. I hope that helps clarify. It 

is a risk-based prioritization process. 

Charles Franklin: Thanks. 

Operator: Your next comment comes from the line of Liz Harriman with TURI. 

Liz Harriman: Hi. I’m a little concerned over your statement about “can’t identify 

significant sources of exposure.” I want to reiterate the concern about the lack 

of robust use and exposure information. The data sources that you have there 

are fairly weak and vague or out of date, and it’s not that I have another 

suggestion of a more robust source for you, but I think it’s really important to 
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focus on the hazard information for which you have more quality information. 

And then just consider exposure qualitatively as a secondary consideration, 

not use it as a screen because there are many things that could be significant 

exposures that are not going to show up on the few sources you have here. 

Operator: Your next comment comes from the line of Mark Mitchell with the National 

Medical Association. 

Mark Mitchell: Yes. I had proposed previously that you look at chemicals that people are 

currently being exposed to, toxics that people are currently being exposed to, 

and that are currently having health effects. And I wanted to talk about data 

sources, particularly for the legacy chemicals. 

 There is the NATA file, the National Air Toxics Assessment, that talks about 

air toxics that people are exposed to. There is RCRA and national priority 

sites, the Superfund sites, and you could get the list of the most common 

exposed chemicals from there. And then, of course, there’s lead poison, the 

lead levels, the blood lead levels that are obtained in many communities 

around the country. But, again, it’s difficult, I think, to assess the exposure 

data. Thank you. 

Operator: Your next comment comes from the line of Tracey Easthope with Ecology 

Center). Tracey Easthope, your line is open. 

Tracey Easthope: I’m sorry, I was on mute. Yes, thanks. I wanted to reiterate a concern about 

still we’re in sea of ignorance around so many end points for chemicals, as 

well as exposure, and so I wanted to support comments that have been made 

already about casting a broader net both on exposure and on hazard end 

points. 

 And I’m wondering whether there’s a way in which this process can move us 

to resolve some of the ignorance. So, for instance, chemicals that are very 

persistent and very bioaccumulative for which we don’t have adequate 

toxicity data but may represent widespread exposure at some point because of 

those properties. So that would be another criteria that I think would be 

important. 
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 But again, if there’s a way to cast a net and then use this process to identify 

areas of ignorance that need to be resolved, then we aren’t just prioritizing 

chemicals based on available information where we don’t have the whole 

story. 

Operator: Your next comment comes from the line of Nelson Lawson with Pine 

Chemicals Association. 

Nelson Lawson: Thank you. I’m just wondering why the whole HPV program doesn’t show 

up on that, on those lists there in Table 1, given that there’s huge amounts of 

both hazard and exposure data from the largest volume chemicals that are 

used in the country and the ones that probably need to be tackled first. Thank 

you. 

Wendy Cleland-Hamnett: Just a clarifying point on that. The HPV data sets show up in the 

Step 2 exposure as use and hazard information. So, there’ll be a chance to 

comment on those in the next part of the discussion. 

Operator: Your next comment comes from the line of Barbara Warren with Citizens’ 

Environmental Coalition. 

Barbara Warren: Yes, this is Barbara Warren. I was hoping that perhaps we could return to the 

question on the nanomaterials that was asked earlier. I was hoping maybe 

EPA could actually answer that question in terms of, you know, the lack of 

information on nanomaterials and what your approach would be to addressing 

them in this, you know, prioritization scheme? 

Wendy Cleland-Hamnett: OK, for nanomaterials, we actually have been reviewing new 

nanomaterials that are placed on the market in our new chemicals program 

under TSCA. And at this point, we’ve reviewed over 100 new nanomaterials, 

so, and as we’ve been reviewing those, where appropriate, actually, for many 

of the nanomaterials, we’ve been both requiring some controls on worker 

exposure, release to the environment and so forth, as well as asking that 

additional data be developed on those. 
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 And then on the existing chemicals part of the nanomaterials world, we have 

several rules under development, two of which would require the submission 

of information on use of nanomaterials, production volume, exposure, etc., as 

well as putting in place a Significant New Use rule under TSCA that would 

require, essentially, the equivalent of the submission of a new chemicals 

notification for certain nanomaterials. 

 We’re also developing a rule that requires some toxicity testing of a sub set of 

nanomaterial, and we’re working internationally with OECD, the 

Organization for Economic Cooperation and Development, on 

characterization of nanomaterials, better understanding exposure. There’s 

some work sharing going on among the participants in that OECD working 

party to share, doing some research and testing on nanomaterials. 

 So there’s actually quite a bit of work underway here in my Office, as well as 

in the Office of Research and Development at EPA, to get a better handle on 

what’s happening out there in commerce with nanomaterials, as well as 

getting a better understanding of environmental exposure, human exposure, 

and toxicity. 

Barbara Warren: Was that Wendy speaking? Is that Wendy? 

Wendy Cleland-Hamnett: Yes, I’m sorry, that’s Wendy. 

Barbara Warren: OK, so thank you. Thank you very much. 

Operator: Your next comment comes from the line of Alex Stone with Washington State 

Department [of Ecology]. 

Alex Stone: Hi there. Yes, two quick comments. One, again, a good reason to coordinate 

with states, we addressed the exposure issue a little bit in what we did as well 

out in Washington State when we identified our chemicals of high concern to 

children, and one way we got around the – or one solution we had was rather 

than try to prove exposure, we used the potential for exposure so that saved us 

from having to prove a direct line of exposure. 
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 But if a chemical is found in humans or, you know, it’s found extensively in 

consumer products, etc., there’s a large potential for exposure and, therefore, 

that sort of gravitated the chemicals that had toxicity criteria, very similar 

toxicity criteria that you’re using in your prioritization scheme, up to the top 

of the list. 

 So I would recommend that – but I thought I read that in what you had written 

as well, but I thought it may be good to emphasize that a potential for 

exposure I think is one way to handle that issue. And then the other thing is 

for criteria, you may want to also include the sensitization criteria. You know, 

skin, eye, respiratory, etc., and one of the reasons is that, you know, there’s 

been a large increase in a lot of these related diseases, asthma and allergies 

and things like that. So there’s obviously a very direct – and for some 

chemicals there seems to be a connection, so I’d include that in your criteria 

as well. Thank you. 

 

Operator: Your next comment comes from the line of Stephanie Castorina with IPC 

[Association Connecting Electronics Industries]. 

Stephanie Castorina): Yes, thank you. I just wanted to make a comment in regards to the risk 

versus hazard discussion and just because there’s a lack of necessary data 

shouldn’t be a justification for using a hazard assessment over a more 

comprehensive risk assessment, and I was pleased to hear EPA say that this is 

a risk-based prioritization process. Thank you. 

Operator: Your next comment comes from the line of Derek Swick with API. 

Derek Swick: Thank you. I have a few comments I wanted to make. First, EPA really 

needs to consider information available from ECHA, the European Chemicals 

Agency, much of which is available on ECHA’s public website through a very 

easy to use chemical substance search mechanism. API would also encourage 

EPA to coordinate with ECA and also industry to leverage work being 

conducted under REACH. 
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 I think the value here is information on exposure. Information developed 

under REACH, specifically the chemical safety reports, is recently generated, 

it’s fresh, it’s new, and certainly for the oil and gas industry and various 

groups of petroleum products, that exposure information is some of the most 

comprehensive information available. 

 My second point, it’s puzzling that ToxCast is not mentioned on the screen 

and in the document. EPA launched ToxCast in 2007 to develop ways to 

predict the potential toxicity and also to develop an approach for prioritizing 

thousands of chemicals that may need toxicity testing. Here EPA should 

carefully consider which data, which approaches, tests and test results and 

other information could be leveraged from ToxCast for this specific EPA 

chemical prioritization activity. 

 And finally, I want to make the point that it’s imperative that any data source 

for prioritization be managed by the public sector or government. I know the 

“Substitute It Now!,” or SIN list, was mentioned earlier and certainly this 

process should not drop from NGO-managed lists to prioritize chemicals for 

further EPA work. Thank you. 

Operator: Your next comment comes from the line of Michael Belliveau with EHSC. 

Michael Belliveau: Yes, Michael Belliveau, Environmental Health Strategy Center. A couple 

of thoughts about data sources. I would think that EPA would want to rely on 

its exposure tasks data base that was announced in June, the data base of 

chemical exposure studies, as an important source of information in addition 

to the toxicity reference data base. 

 Also I’m wondering, I didn’t see any mention in the discussion guide of 

reliance on the peer reviewed scientific literature. I would think that EPA 

would want to be open to relying directly on such primary research, you 

know, of course, a lot of the NIEHS-funded research is published in 

Environmental Health Perspective as well as there being many other credible 

journals. You know, shouldn’t that be included as well? 

Operator: And there are no further comments. 
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Wendy Cleland-Hamnett: All right, thank you, Tameka. We’ll move then to – in the agenda, 

we talked about having a break between the Step 1 discussion and the Step 2 

discussion, but given that we’re running ahead of our schedule here, I’m just 

going to decide that we’ll move on and discuss Step 2 and work through that 

and depending on how long that takes we could take a break or we could just 

have an early conclusion to the discussion. 

 So, Step 2, we have data sources that we would use to take that more refined 

look to help us decide our priorities for work within the number of chemicals 

that are identified in Step 1. 

 So again, we have some slides, but I’d encourage you to look at the discussion 

guide that was provided, if you printed that out or it can be pulled up on our 

website, to look at the tables in the discussion guide. 

 So again, we’re looking at questions such as are there additional data sources 

beyond those listed in Tables 2 and 3 that should be considered? Should any 

– are any of them not appropriate from your perspective and that would be 

helpful to know why you think that should be the case. And are there certain 

data sources that should be considered more important in the agency’s 

analysis than others? And why you would see that to be the case or not. 

Thanks. 

Operator: Again, to make a comment, please press star 1. Your first comment comes 

from the line of James Cooper with the National Petrochemical & Refiners 

Association. 

James Cooper: Thank you. It’s not just a question of data sources. I think something that 

would benefit both the agency and all stakeholders is the agency establishing 

- and this could be true a multi-stakeholder process - but establishing a set of 

criteria by which data sources and the data itself be judged and make it as 

transparent as possible because there are many different lists out there, many 

different data bases. 

 And, you know, some of the lists may be older data bases, some have been 

called into question because of sampling or sampling sizes or things of that 
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nature, especially when you get into some of the older biomonitoring 

databases. 

 So I think if the agency where to develop and publish criteria and open it up 

for comment or stakeholder input, that would create a lot of transparency and, 

you know, allow the agency then to actually weight different data and, you 

know, those weighting factors should also be transparent. And, I think, it 

would serve the agency well in the long run, that way a lot of the decisions 

would be well understood and not called into questions so much. Thank you. 

Wendy Cleland-Hamnett: This is Wendy. Just before we go to the next comment, I’ll 

provide the web address for the discussion guide for those of you who might 

not be able to access it right now. It’s blog.epa.gov/chemprioritization, I think 

that’s all one word. C-h-e-m-prioritization. Thanks. 

Operator: Your next comment comes from the line of Melanie Marty with CA EPA. 

Melanie Marty: Hi, this is Melanie from CAL EPA. Just a reminder that there are a lot of 

other state level data bases for environmental exposures, including air 

monitoring networks in California and elsewhere, and water monitoring 

networks in California and elsewhere. And I realize we’re one state but one in 

eight people live here, so - one in eight people in the United States lives in 

California. 

 And ditto the risk assessment activities in California, Minnesota, 

Massachusetts, Connecticut, New York, there’s other states that have done 

publicly and peer reviewed assessments of chemicals that haven’t been done 

by the USEPA, so there’s another source and I’ll send in those sources into 

the blog so you guys can get them. Thanks. 

Operator: Your next comment comes from the line of Erin Yager with Pratt & Whitney. 

Erin Yager: Yes, I just wanted to reiterate the comment that I also do not believe that 

NGO-managed lists should be considered as data sources but that the EU data, 

particularly that derived through REACH, should definitely be considered 

here, just it would help, I think, companies trying to comply with all of these 
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regulations to have a more international approach than to have to follow 

different regulations throughout every country. So harmonization would 

definitely be advantageous. 

Operator: Your next comment comes from the line of Carlos Thomas with SEHSC 

[Silicones Environmental Health and Safety Council of North America]. 

Carlos Thomas: Hi, this is Carlos Thomas with SEHSC. I really wanted to reiterate a couple 

of the comments that were made earlier, with respect to the data sources. And 

I think this is true with the data sources used for Step 1 and Step 2, so I really 

think all of these data sources should really be held to extremely high 

standards with respect to, not only scientific veracity, but also peer review 

because I really think some of the market place implications associated with 

an inappropriate indictment of these chemicals really can’t be understated. 

 Some of the sources that have been listed really have not been subject to peer 

review, some of them haven’t been opened to public scrutiny and then some 

of the other ones also rely on either modeling techniques or using physical 

chemical properties as surrogates for environmental behavior. I think we 

really need to look at that very carefully before we seriously consider any of 

these sources. Thank you. 

Operator: Your next comment comes from the line of Derek Swick with API. 

Derek Swick: I’d like to make another comment with regard to a few of the international 

comments made earlier. Looking through the discussion guide, there is no 

mention of the prioritization efforts of other countries, specifically Canada, 

Japan and Australia. I do note that from our perspective, Canada is ahead of 

the U.S. in the area of chemical prioritization. From 1999 to 2006, the 

Canadian government completed prioritization of approximately 23,000 

chemicals on its Domestic Substances List. And the Canadian government is 

now in the process of further assessing 4,300 chemicals, approximately, 

through its chemicals management plan. We would encourage EPA to look to 

Canada for both data sources and categorization approaches. 
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 A more specific comment I have is on the data sources in Table 2. I have 

some concerns about how EPA might use data from the Toxics Release 

Inventory, the TRI, for the prioritization process. The TRI comprises data on 

releases and transfers of chemicals reported annually by facilities subjected to 

the TRI reporting rules. 

 EPA and others have used TRI data, in many models and analyses that range 

in quality. Some are good, some not so. One recent example is EPA’s RSEI 

model, or the Risk Screening and Environmental Indicators tool, which EPA 

has essentially developed as a screening risk type model combining TRI data 

with hazard data. 

 We mention RSEI here only as an example of what can and does go wrong 

when EPA attempts to take TRI data and build models around it as a substitute 

for conducting proper human risk assessment. And the concern is that taking 

the TRI data with hazard data and not doing a risk assessment, I think what 

can result potentially is garbage and we certainly do not want that through this 

prioritization process. We don’t object to TRI as a data source as long as it is 

used within its limitations and in a scientifically sound manner. Thank you. 

Operator: Your next comment comes from the line of Lin Kaatz Chary with Great Lakes 

Green Chemistry Network. 

Lin Kaatz Chary: Thank you. I just wanted to reiterate a couple of things that people have said. 

I’m extremely concerned about any drift away from looking at hazard and 

focusing weighting exposure more heavily. And the reason for that is that not 

only do we not have a lot of information about exposure, but the information 

that we do have on exposure has been changing very rapidly over the past 

several years. 

 As we learn more, we have discovered that chemicals which we did not think 

had exposure potential, in fact did turn out to have exposure potential. And 

the PBT chemicals, PBDEs, are some of the examples of that. So I think it’s 

really important to take into consider the hazard of chemicals and that relates 

to the question of biomonitoring also where I really think we have to put some 

emphasis on that because one of the deficits that we have in understanding 
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exposure information is that there are different ways - is that we don’t have a 

lot of information about synergy of chemicals interacting. 

 We don’t know – we aren’t – traditional exposure models do not show us 

information about generational exposures. They also - traditional exposure 

models focus more on linear dose response models and don’t take into account 

timing of exposure which can be very significant. 

 So I’m not, you know , speaking in favor of just putting any chemical willynilly on a list – excuse me, I’m sorry - but I do think there has to be a very 

critical balance to understand the shortcomings of exposure and that’s why we 

lean toward – why we really encourage looking at the hazard potential of 

chemicals because something that we say does not have exposure potential 

now - doesn’t have x, y, or z pathway now - we may discover next year or in 

a couple of years that we were incorrect about that, and especially with those 

chemicals with which we have so little information in general. 

 So I really wanted to reiterate those, you know, my support for really focusing 

on a hazard perspective and really understanding that, you know, when we 

make a mistake about exposure, it’s usually an irrevocable mistake. We can’t 

go back and unexpose people. But if we make a mistake about hazard, we can 

always take something that we thought was hazardous off the list and, 

therefore, I really do – I agree with having peer reviewed data but also to 

really understand the question of biomonitoring. 

Operator: Your next comment comes from the line of Liz Harriman with TURI. 

Liz Harriman: Hi. So I would hate for EPA to hold up the process by trying to evaluate each 

data source and check for peer review and check for quality. I think if you 

have information, you should just feed it in. Because of all the data gaps and 

all the questionable data from all sources, I’d encourage EPA to do a reality 

check when you get done. 

 Don’t rely strictly on a particular ranking methodology. Instead, apply expert 

judgment to your results when you get done, understanding the information 

that went in. I think that will help address both the concerns of the NGO 
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community about the lack of information and about the industry community 

concerns with sources that aren’t necessarily of the highest quality. 

Operator: Your next comment comes from the line of Michael Belliveau with EHSC. 

Michael Belliveau: Yes, thank you. EPA has listed some very good data sources, some others 

have been suggested by the commentors. I don’t really see a discussion in the 

discussion guide regarding how exposure data, for example, how those data 

will be used. I would strongly urge EPA to consider aggregate exposure to a 

given chemical from all sources including non-TSCA sources for purpose of 

prioritizing because this of course mirrors real world exposure and, you know, 

please don’t parse apart limited exposure sources but consider them in 

aggregate. 

 Another comment, I’m sure EPA will apply appropriate caution to the 

Inventory Use Reporting data. The chemical use information in there is not 

generally specific enough and exposure data, although it may shed some light 

in some cases on work exposures of concern, is also extremely limited and the 

new chemical data reporting requirements won’t become fully operative for 

several years. So please apply caution to IUR data. 

 And lastly, with regards to the comments by several of my colleagues 

regarding what a great job Canada has done. I would encourage them to join 

us in achieving a meaningful reform of the Toxic Substances Control Act 

[TSCA]. 

 You know, Canada’s multi-year process followed amendment of their federal 

statute and until we get TSCA reform, EPA’s only going to be able to do 

limited things with regards to prioritization. I think, basically, they’re on the 

right track with this proposal. Thank you. 

Operator: Your next comment comes from the line of Georjean Adams with EHS 

Strategy. 

 Georjean Adams: I’d like to get some clarification. I thought when you opened up, Wendy, you 

were talking about this as being a way to prioritize chemicals that have known 
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risk and to identify those with the highest risk, i.e., something that might drive 

toward a SNUR or Section 6 rule or the like, as opposed to the prioritization 

system that will drive towards identifying where we need to collect more 

information about either toxicity or exposure to a tailored Section 8 rule. 

 If the focus is on known risk, i.e., information that you have in your 

possession through these various data bases, then I think you’ll come out with 

some chemicals that, yes, need action now. And you can proceed through all 

the different tools that you have. If it’s identifying chemicals that you would 

default to an assumption of high risk, then I think it’s a different ballgame 

entirely. 

 I think you’re much better off, and we would actually get some things 

accomplished, if we focused on known risk and started whacking those down 

and then have the parallel separate path that is looking for how to collect 

better information on both toxicity and exposure. 

Operator: Your next comment comes from the line of Pamela Schwingl with REACH. 

Pamela Schwingl: Hi, I wanted to agree with the previous speaker about not holding up the 

process with a lengthy review of all the data sources but there’s a parallel - in 

the parallel world of epidemiology studies and evaluating clinical trials using 

meta analysis. 

 You know, you can - there are weighting factors and there is a very 

formalized method, but there’s also more qualitative review, and I would 

suggest that there would be extra panels that could look at a more qualitative 

review after some selection and to weight these, to weight these data sources. 

So I would not want to hold up the process for a lengthy evaluation of the data 

sources first. 

Operator: And there are no further comments. 

Wendy Cleland-Hamnett: OK, I would just before we close, I would offer one more time if 

there are folks who haven’t had a chance to speak yet or if you want to make a 
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33 

general comment before we close the webinar, now would be your 

opportunity and then I’ll just make a brief closing remark. 

Operator: Again, to make a comment, please press star 1. Your next comment comes 

from the line of Kate Winnebeck with the New York City State Pollution. 

Kate Winnebeck: Hi, this is Kate Winnebeck from the New York State Pollution Prevention 

Institute. And my comment is more, I guess, for the whole process in general. 

And I would be really interested in, kind of stepping back and looking, or 

maybe it’s really at the end, how you’re going to prioritize some of these 

attributes, I’ll call them. You know, at the end of Step 2, you’ll have 

hundreds of chemicals, maybe a thousand chemicals, and kind of have bits 

and pieces of information for each one of those. 

 You know, what’s really the next step and how do you prioritize that and 

really get a manageable number? You know, so I’m really looking forward to 

how that process is going to work as well. Thank you. 

Operator: Your next comment comes from the line of Pat Rizzuto with BNA. 

Pat Rizzuto: Actually it’s Pat Rizzuto with BNA. Hi, Wendy. 

 I’m just curious. After EPA has gathered these lists of chemicals that will be 

the Step 2, that will have completed Step 2, come out in the fall, how do you 

deal with the absence of information? Under the FIFRA scheme, there are 

consequences if a pesticide does not have data. How do you provide 

incentives under TSCA for companies to provide you that data? 

Wendy Cleland-Hamnett: This is Wendy. Well, I think I mentioned earlier in the 

presentation during the beginning of the discussion that there’ll be a 

timeframe after we provide the list of priority chemicals that we’ll be working 

on, where we’ll provide, here’s the data that we - or the sources of information 

that we intend to use to inform our review and assessment. And at that point, 

there’ll be a time where if folks believe there is better information, more up to 

date information, information we haven’t seen before, that they’ll be able to 

provide to us before we do a more in depth review. 
U.S. Environmental Protection Agency Transcript: Chemical Prioritization Webinar

34 

 So I think in some ways, that’s similar to the Canadian process where they 

basically said, here’s the information we have and we’ll be proceeding with 

this information unless other information is provided for us to consider. 

 So I think if folks want us to be using, you know, the most accurate up to date 

information and they believe they have information of that type that EPA 

doesn’t have, there’ll be an opportunity for them to provide it. 

Pat Rizzuto: So the incentive is a built in, sort of a worser case, we’ll make worser, more 

risky conclusions, unless you provide us the data. 

Wendy Cleland-Hamnett: Well, yeah. We’ll use the best information that we have available 

to do that. And, you know, unlike the pesticides program, which is a 

registration program, we’re not a registration program, so we don’t require a 

set of information for every existing chemical that’s on the Inventory. So we 

are in a different position with TSCA than in the case of FIFRA and the 

FFDCA . 

Pat Rizzuto: Thank you. 

Operator: Your next comment comes from the line of Tyrone Wilson with Portland 

Cement Association. 

Tyrone Wilson: Yes, thank you. My question goes back to, I guess, the comment that was 

made at the start of the webinar. I think the presenter mentioned that the, that 

this information was going to be placed in the docket at some point. Can you 

give us some indication about the timeframe for that and, you know, when all 

of this material will be accessible through the docket. Thank you. 

Operator: Your next comment comes from the line of Liz Harriman with TURI. 

 Liz Harriman: I just want to thank EPA for the work on the chemical action plans to date. 

The ones that you’ve done so far have been very helpful. I appreciate the 

focus on action and on safer alternatives. We would rather that EPA spend 

their precious resources trying to move us forward towards safer alternatives 

rather than dwelling on getting every last piece of data and information on 

things that could probably be better substituted with safer substitutes. 
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35 

 And in line with that, in terms of the expert judgment, you can’t make a 

criteria out this, but the likelihood of wreaking havoc down the road is 

something that we try to pay attention to in Massachusetts. And there are 

definitely some substances out there that may not end up scoring super high 

because of a lack of data, but certainly have the likelihood of really being a 

next generation significant problem. Thanks for all your hard work. 

Operator: Your next comment comes from the line of Haroon Mahgerefteh with 

Infineum. 

Haroon Mahgerefteh: Hello, it’s Haroon. I had a general comment in regards to all of these 

efforts. When that - for completing this effort, you always need to consider 

minimizing the amount of animals and preferably use the models. The second 

thing is the harmonization that we need to conduct our actions and align all of 

these efforts with EU REACH to minimize the burden on the industry. Thank 

you. 

Operator: Your next comment comes from the line of Sarah Brozena with ACC. 

Christina Franz: Hi there. This is Christina Franz from ACC, actually, participating with Sarah 

Brozena of ACC. We attended the session in person this morning and won’t 

take up much time here, but we did want to alert the participants in this 

webinar that ACC has developed a prioritization tool which integrates hazard 

and exposure and identifies or evaluates – proposes to evaluate chemicals 

against objectives, comprehensive criteria, and we have posted that on EPA’s 

blog and are offering that as a supplement to augment EPA’s work in 

prioritization and once again, we want to thank EPA for hosting this dialogue 

and hope that it will be something that we will continue in the future. Thank 

you. 

Operator: Your next comment comes from the line of Michael Belliveau with EHSC. 

Michael Belliveau: Thank you. I thought the brief exchange between Pat Rizzuto and Wendy 

was really illustrative. Pat, you put your finger on the crux , the weakness of 

our entire chemical management system which is that right now, all the 
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36 

incentives are to not generate data and so it’s important that this exercise that 

EPA has proposed overcome that disincentive to provide data. I think one 

way to do that is to be prepared to list on your candidate list of chemicals in 

Step 1, those chemicals for which we have partial data, if, for example, a 

chemical for which you know has high hazard but we are lacking for the time 

being any publicly available exposure data, or chemicals that we know the 

public is widely exposed to but we don’t know enough about the hazard. In 

proposing or naming such chemicals, this will in turn create an incentive for 

those that have access to such data or who have a stake in continued use of 

that chemical to step forward and provide data, which is what we need. So 

please be prepared to do that to overcome this barrier. Thank you. 

Operator: And there are no further comments. 

Wendy Cleland-Hamnett: Well, this is Wendy. I just want to, again, thank everyone who has 

been on the line with us today, particularly those who’ve provided comments 

and suggestions and questions. We very much appreciate the thought that 

you’ve put into this. Lots of thoughtful suggestions and questions that we’ll 

be taking into consideration, and we very much appreciate it. 

 In response to one of the last few comments, there was a question. We will be 

posting a summary of what we’ve heard in the course of this webinar, in 

meetings that we’ve had, and also posting comments that are posted to the 

discussion blog. The discussion blog, if you are interested in providing 

further written comment, will be open through 5:00 p.m. on September 14, 

[2011]. 

 So if there’s additional information, there’s an ability if you want to provide 

links to data bases, articles, so forth and so on, you can do that in the 

discussion blog and we’d encourage you to do that. 

 So the summaries, we plan to be posting within several weeks of the close of 

the discussion blog. So, that would be, we hope by the end of the month or 

shortly thereafter. And I think that’s it, unless, John, there is anything else we 

need to mention. Again, thanks to everyone for caring about the work that we 
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37 

do here. It’s very important work, and we’re glad that you’ve shared your 

thoughts with us on it. And with that we’ll close the discussion. 

Operator: Thank you all for participating in today’s conference call. You may now 

disconnect. 

END