UNITED STATES OF AMERICA

ENVIRONMENTAL PR OTECTION AGENCY

PUBLIC MEETING TO DISCUSS ENHANCEMENTS TO ChAMP

EXECUTIVE SUMMARY

MONDAY, DECEMBER 8, 2008

EPA POTOMAC YARD

2777 CRYSTAL DRIVE

ROOM S-1204 ARLINGTON, VIRGINIA

PRESENT:

CHARLES AUER, Director, Offi ce of Pollution Prevention and Toxics (OPPT) WENDY CLELAND-HAMNETT, A ssistant Director, OPPT JAMES B. GULLIFORD, Assistant Administrato r, Office of Prevention, Pesticides, and Toxic Substances (OPPTS)

OSCAR HERNANDEZ Di rector, OPPT Risk Assessment Division LOUIS (GINO) SCARANO, OPPT Risk Assessment Division JIM WILLIS, Director, OPPT Chemical Control Division KEN MOSS, OPPT Chemical Control DivisionWELCOMING REMARKS

Charles Auer called the meeting to orde r in room S-1204 of 2777 Crystal Drive, Arlington, Virginia, at 1:01 p.m. The purpose of the meeting was to discuss enhancements to ChAMP (Chemical Assessment and Management Program), including the IHPV (Inorganic High Production Volume) Challenge Program and the reset of the TSCA Inventory. He encouraged oral and written comments from the public.

EPA'S CHEMICAL ASSESSMEN T AND MANAGEMENT PROGRAM

Mr. Gulliford recognized Mr. Auer’s years of se rvice and upcoming retirement. Ms. Cleland-Hamnett will serve as acting Director of OPPT. The ChAMP program grew out of the SPP (Security and Prosperity Partnership) and is a fundamental part of the agency's chemical regulatory framework under TSCA. At the SPP Summit in August, 2007, Presiden t Bush, President Calderon, and Prime Minister Harper announced new initiatives for chemical management in North America. The commitments will benefit US, Canada, and Mexico by increasing knowledge about

chemicals and their use. Canada and US have committed to working with Mexico to establish a Mexican Chemical Inventory and a strengthened North American chemical regime; to encourage research and devel opment on new approaches to testing and assessment; and to create mechanisms to share domestic scientific information and best practices for chemical assessment and manage ment, as well as to enhance Mexico's assessment and management capacity.

US commitments under SPP call for EPA to assess and initiate needed action on the over 6,750 chemicals produced at above 25,000 pounds per year in the US, a threshold that includes both HPV (hi gh production volume) and MPV (moderate production volume) chemicals. The screening le vel decisions will be publicly released. EPA will take actions as needed. RBPs (Ris k-Based Prioritizations) for HPVs and HBPs (Hazard-Based Prioritizations) for MPVs will be the source of initial actions. This is to be done by the end of 2012. ChAMP encompasses the US SPP commitments, but EPA has been looking at

additional initiatives to enhance the chem ical program, including an HPV challenge program for inorganic chemicals and a resetti ng of the TSCA inventory. The work will build on and benefit from prior work, such as the original, organic chemical HPV Challenge Program, Canada's categorizati on work, and the production information on inorganic chemicals obtained from the most recen t IUR (Inventory Update Rule). The ChAMP screening decision pro cess for assessing and prioritizing HPV chemicals uses hazard data from the HPV Challenge and exposure information from the IUR to develop RBPs. The program is in the process of evaluating potential risks associated with each chemical – for prioriti zation purposes - to dete rmine whether it is a high priority, special concern chemical. TSCA authority may be used to ask for additional data or testing as needed. Contro l measures will be implemented or required as needed, and low priority chemicals can be set aside to be reexamined if new data warrants reexamination. EPA will post the a ssessments and conclusions on the agency website, and stakeholders can comment and submit data electronically.

2A number of tools are available for RBP implementation. EPA has authority under TSCA and the Pollution Prevention Act to take regulatory and non-regulatory actions. EPA can interact with industry to develop HPV Challenge-like programs or programs like Design for the Environment to a ssess and reduce risks associated with the

use of chemicals. For MPV chemicals, a different approach is being develope d that will rely on

hazard and fate assessments from the Cana dian categorization results and EPA's SAR (Structure Activity Relationships). Hazard Characterizations (HC) will be used to identify MPVs that require follow-up, either gathering of additional data or risk management through the public posting of HBPs. As of November 2008, HBPs on 38 MPV chemicals have been posted. ChAMP has focused on developing a pro cess for meeting SPP goals. As of the meeting (12/8/08), 190 HCs, 151 RBPs, and HBPs for 38 MPV chemicals had been posted. The goal for 2009 is to continue posting RBPs for HPV chemicals and to ramp up the posting of MPV HBPs. In March of 2008, EPA Administrator Johnson announced plans to seek input from a wide range of partners and stakehol ders on possible ChAMP enhancements. EPA conducted meetings, discussions, and webcas ts around the country and in D.C. In September, Administrator Johnson announced the decision to go forward with two enhancements. One enhancement is to update the TSCA inventory by resetting it to better reflect the chemicals currently in comme rce in the US. The other is to develop a phased approach to challenge the US chemical industry to develop health and safety data on inorganic HPV (IHPV) chemicals. In both of these efforts, EPA will seek comment and engagement from stakeholders. ChAMP is not a substitute for the HPV Challenge program. The intent is to complete data sets for the HPV Challenge program, and that data will be part of ChAMP's screening. ChAMP works closely w ith its Canadian and Mexican counterparts on the SPP commitments, and REACH submitters and evaluators will benefit from US

and Canadian work. The schedule for Nort h American assessment work compares favorably to REACH's registration schedule. US, Canadian, and European leaders met in 2007 and 2008 to discuss ongoing cooperation.

PROPOSED APPROACH TO THE INORGANIC HIGH PRODUCTION

VOLUME CHALLENGE PROGRAM

Mr. Auer called for the panel for the IHPV Ch allenge program, which consisted of himself, Gino Scarano, and Oscar Hernandez. Dr. Scarano presented on the proposed approach for the IHPV challenge program, starting with a definition of inorganics. TSCA defines a chemical as inorganic if it does not contain carbon or contains carbon only in the form of -CO3, -CN, -OCN, -NC, or -NCO groups or chalcogen analogues of such groups. The IHPV Challenge program is an enhancement to ChAMP that is intended to characterize the toxicity, e nvironmental fate, and physical-chemical properties of inorganic chemicals that are manufactured or imported into the US at volumes greater than a million pounds per year. Over the last ten years, the HPV challenge program focused on about 2,800 organic chemicals. The 2006 IUR included re porting on production volume of inorganic

3chemicals for the first time. Preliminar y figures show there were 763 inorganic submissions, 446 HPV, 317 MPV. The 2011 IUR will include use and exposure information for inorganics. EPA's thinking is outlined in the document, “ Proposed Approach for the Inorganic High Production Volume (IHPV) Challenge Program ,” which is available at www.regulations.gov under docket EPA-HQ-OPPT-2008-0807). EPA seeks written and oral comments on the proposal and is committed to finding and working with

stakeholders. The IHPV Challenge Program was proposed as a three-phased process: Phase 1, development, launch, and sign-up, will be in 2009; Phase 2, implementation of the challenge, which would include receiving and reviewing data, will run from 2010-2013, using section 4 of the TSCA test authority vigorously for unsponsored chemicals; and Phase 3, running 2013-2015, will be for assessm ent and initiation of needed actions. IHPV data and IUR exposure information will be considered, and the information will be used for a risk-based prioritization. MPV i norganics will be subs equently assessed and prioritized. The remainder of the presentation focused on Phase I. Current thinking is that the program will be designed to take full advantage of OECD (Organization for Economic Coope ration and Development), Canadian Categorization, and REACH work; use the clus ter approach from the MPV effort; and

use information available from other sources , including feedback from this meeting.

OECD. OECD established its HPV Program in 1991, and it was the basis of the US HPV program. OECD developed an inte rnationally-accepted Screening Information Data Set (SIDS). To date, there are 887 co mpleted assessments in the international forum, 616 of them posted. There are about 160 inorganics in the OECD HPV program; 109 have gone through the process and 51 are in the inform ation-gathering or da ta review phase.

OECD's information will be useful to th e proposed program. Additionally, OECD's guidance will be a useful starting point for IHPV guidance. OECD's SIDS for organic chemicals looks at four parameters: physical-chemical properties; environmental fate; environmental e ffects; and health effects. Some of the properties will not apply to inorganic chemi cals, and EPA seeks input on that specific issue. OECD has identified parameters to be considered in describing the physicalchemical properties of inorga nic chemicals: degree of dissociation of metal-containing compound; chemical speciation and valency; crys talline structure, pa rticle size, and in vitro solubility. EPA will consider and re fine OECD's recommended approach to come up with the best way to describe the h azard of an inorganic, probably focusing on physical-chemical properties, environmental fa te, and bioavailability. Canadian Categorization Effort. The Canadian Environmental Protection Act of 1999 required Canadian authorities to prioritize 23,000 chemicals on the DSL (Domestic Substances List) in 2006. EPA will apply these results to the IHPV program,

where relevant.

REACH. EU's REACH (Registration, Evaluati on, Authorization, and Restriction of Chemicals) law went into effect in 2007. EPA has discussed collaboration with the European Commission and the European Chem icals Agency and will look at inorganic chemicals submitted for information relevant to the IHPV program.

4ChAMP/s MPV Effort. ChAMP's MPV HBP (hazard-b ased prioritization) groups chemicals into clusters based on struct ure. Relatively data-rich chemicals are clustered for data-sharing purpos es. EPA is considering a similar approach for inorganics and will look for comments from stakeholders on the clusters that EPA develops and

proposes. Dr. Scarano directed the audience to EP A's Risk Assessment Forum and OECD's guidance on categories for other information. The goal is to have reviewed the OE CD, Canadian, and REACH information and EPA-proposed clusters for inorganic HPVs by late summer of 2009. In the fall, EPA will host a workshop to discuss the issues and refine the approaches. Then EPA will initiate the sponsor sign-up and implement the program.

DISCUSSION OF PROPOSED APPR OACH TO THE IHPV PROGRAM

Mr. Auer opened the floor for questions and comments. Dr. Kristie Sullivan from the Physicians Committee for Responsible Medici ne said PCRM supports the clustering approach. She asked about the in vitro solubi lity studies with regard to lung, stomach,

and intestinal fluid. Dr. Scarano said the studies would be in vitro. Dr. Sullivan said she would submit any further comments in writing. Mr. Auer emphasized that the categories of chemicals would be EPA-designed, not sponsor-designed, though EPA would get input. The industry would then sponsor all of the chemicals in a given cluster. This may cause challenges, since certain chemicals in a cluster may not be relevant to a given segment of industry. EPA is interested in us ing this method of clus tering and trying to identify and work through the issues the method raises. Dr. Sullivan said the new categorization process will prevent si milar chemicals from being submitted independently with different test plans, as occurred with the HPV program.

Jim Cooper from the National Petroleum Refiners Association expre ssed appreciation

for Mr. Auer's work and said that it had been a pleasure working with him. He felt encouraged that EPA was learning from the pa st and applying less ons learned to other chemical groupings--for example, using the word “clustering” instead of categories. He said the stakeholder process was a valuable experience and hoped that it would continue to be used. He suggested looking at timelines from prev ious programs, since some sponsors did not understand the complexities of setting up test plans and that some products are more difficult to test. He said he assumes there w*ill be consistency among the HPV and IHPV programs. He said he liked the idea of allowing arguments for certain endpoints based on physical propertie s, especially to minimize the unnecessary impact on animals in the testing.

Pat Cosano from Corporate Environmental Programs for GE asked about opportunities for public comment on the criteria by which ch emicals are being evaluated in the current ChAMP effort and the IHPV program. She asked in particular about how to submit information relevant to a particular chemical before EPA posts the RPB. Mr. Auer said the enhanced website will give the opportuni ty for direct comment on specific RBPs or HPVs. In 2009, EPA will work to post the chem icals it plans to assess in a forthcoming

5period to allow for comment. He felt that will aid EPA in planning and for industry and NGOs to anticipate which chemicals will be coming through.

James Conrad from Conrad Law and Policy Council asked if the program will automatically apply the results of the Canadian Characterization. Mr. Auer said that EPA would look at the results, judge them , and apply them when appropriate. Mr.

Conrad asked what the benefit of the IHPV Challenge program would be if REACH was collecting the same data the IHPV Challe nge was collecting a nd testing the same

chemicals. Mr. Auer said more would be known once the European Chemical Agency has gone through the pre-registration informati on. There is likely to be considerable overlap between the two programs, but the ex tent of the overlap is unknown. More will

be known at the end of 2010

PROPOSED APPROACH FOR RE SETTING THE TSCA INVENTORY

Mr. Auer called for the panel on resetting the TS CA inventory, which consisted of Jim Willis, Ken Moss, and himself. Jim Willis recognized Mr. Auer's leadership in getting EPA to a point where TSCA inventory reset is possible. TSCA Section 8(b) requires that EPA compile, keep current, and publish the TSCA inventory. Historically, EPA has kept the inventory current by adding new chemical s as they went through the new chemicals program and Notices of Commencement were fi led. At the time of compiling the initial inventory, the inventory had about 62,000 chemicals. More than 21,000 chemicals have been added through the new chemicals review program since 1979. In 1986, EPA promulgated the Inventory Update Rule (IU R), which requires companies to update production volume data for certain chemicals in the inventory. He referred the audience to the background document, “Background Discussion Piece: EPA's TSCA Inventory
Reset,” which outlines EPA's current thin king on the reset (available at www.regulations.gov under docket EPA-HQ-OPPT-2008- 0807). EPA seeks oral and written comments on the current thinking. The Inventory supports many TSCA regul atory functions an d must be kept current. The proposed clean reset approach will create a better tool to help EPA perform

its mission. It will allow EPA to review chem icals that might be returning to commerce after having been removed from the inventor y and will allow EPA to take action, when appropriate, to control risks or require test ing. The reset and the final result should be useful to EPA's mission, useful to stakehol ders, should not penalize stakeholders, should be fast and easy to implement, should be low burden to EPA and the reporting companies, and should be consistent with TSCA. At this point, EPA is seeking initial r eactions to general idea s and has not locked into any particular course of action. An a pproach will be proposed in six months and released for comment before the approach will be finalized. The current thinking is that the public version of the Inventory will be posted online with CAS or accession numbers

and chemical names. Generic names can be used when the chemical name is confidential. Companies would have a period of time to certify via a secure website that they had manufactured a chemical listed on the inventory within a pa st time period (three years is the current suggested period). The interface will be very simple. At the end of the certification period, EPA will process the cer tifications and produce a new online

6reset TSCA inventory, containing only chemical s that have been certified by one or more companies. There would be a limited time period for corrections. After the reset, PMN or other TSCA section 5 notice will be requi red prior to manufact ure of any non-exempt

chemical substance after it had been removed from the inventory.

The reset will be coordinated with the IUR reporting period, June through September of 2011, since having the reset i nventory online would alleviate chemical identification problems and allow us to get th e IUR data out to the public faster. We

would like comment on how far in advance of the IUR reporting deadline we should implement the reset program and how we can make this less burdensome for companies. Subsequent resets can be timed to occur in conjunction with IUR reporting. The reset may lead to increased requests for corre ct CA index names, CASRNs, and TSCA Accession Numbers, especially when comp anies cannot find their chemicals in the inventory. EPA will have to accommodate the increase in inquiries and Notices of Bona

Fide Intent to Manufacture.

EPA has looked at alterna tive approaches to the rese t and is asking for comment on those approaches. Under TSCA section 8( a), EPA could issue a reporting rule to require manufacturers to report all chemi cals manufactured during a specified time period. However, this approach would be more burdensome and would create an incomplete dataset due to small business exemptions. Rather than removing chemicals from the inventory, EPA could maintain a list of

active and inactive chemical substances or issue a Significant New Use Rule (SNUR) for all or some inactive chemical substances. However, that approach might be more burdensome than the current plan. EPA is seeking comment on alternatives to the manufacturer certifying chemicals manufactured in a past period, such as certifying intended fu ture manufacture. EPA also is seeking comment on what procedures to follow in allowing corrections during a limited time period for errors inadvertently introduced during the reset, if such a correction cycle should be provi ded. Since EPA is required to “compile, keep current, and publish a list on each chemical substance wh ich is manufactured or processed in the United States,” EPA is asking for comment on how it should address chemicals that are processed in the US but not manufactured here.

DISCUSSION ON THE INVENTORY RESET

Mr. Auer opened the floor for questions and comments. Tom Johnston of McKenna, Long & Aldridge asked about th e section of the inventory for inactive chemicals and whether a special category could be made fo r chemicals that are not of concern, which would expedite resurrec ting those chemicals. Mr. Willis said the thought had been

discussed and EPA invites comment on that. Mr. Auer said there are several ways the

inactive list could work. Ted Thiagarajan of MBC of Malaysia asked ho w foreign manufacturers could get involved. Mr. Moss said a domestic representative or agent would be needed to supply the Pre-manufacture Notification. Mr. Auer said foreign manufacturers often work with the importing entity. EPA's curre nt goal is to make it easy for foreign manufacturers by using approaches consis tent with those already in use. Dirk Bouma of the BMT Reach program followed up on the question of representatives for foreign

7companies. Mr. Auer said the issue had not been fully considered. The approach EPA develops will ensure that foreign companies are not disadvantaged and that any chemicals imported into the U.S. during the reporting period will be accurately reflected on the inventory.

Mark Duvall from Beveridge and Diamond asked about documentation requirements to back up the ce rtification of manuf acturers during the reporting. He also asked about the need for maintenance of proof of manufacture for th e original inventory reporting period. Mr. Willis said EPA had assumed that companies would maintain records that would verify manufacture in th e regular course of business and had not thought about prescribing specifi c record maintenance. As for records from the original inventory, Mr. Willis said he could see instan ces in which maintaining the records can be useful, such as to document that a correcti on to the Inventory may be needed to add a

chemical that should have been includ ed by EPA in the in itial Inventory.

Herb Estreicher of Keller & Heckman suggest ed carving out categories of substances that are exempt from IUR, such as polymers and biochemicals. Mr. Willis

said that should be considered and comment on it would be welcome. Mr. Estreicher said there should be a way fo r a foreign manufacturer to provide chemical composition information directly to EPA without disclosing it to the customer.

Pam Buster read questions from the webinar audience. The first question was whether, for MPVs, hazard-based priori tizations would be listed publicly. Mr. Auer said they would. The second question was whethe r industry would have an opportunity to contribute in-house safety data. Mr. Auer said the opportunities are available. The third comment from the webinar audience was that, due to the multiple errors in the initial inventory compilation, the reset should provide at least two correction periods for data erroneously submitted or erroneously processed. Mr. Auer said the goal is to develop a process that will be simple but adequate. Correction is important, but the correction process cannot be open-ended. Discu ssion on this issue will be important. Mr. Willis said the current inventory has gone through mu ltiple correction cycles , and it will be the starting point for the reset. Th at should reduce errors.

GENERAL DISCUSSION AND PUBLIC COMMENT

Mr. Auer opened the general discussion. Larry Culleen commented that he hadn't heard any discussion on the timing and that th ere are several activities that are underway

that have to be worked into the reset. He suggested considering mechanisms for dealing

with issues that are similar in nature. He said that it is not clear how phosphors and other products that are subject to so me discussion will fit in. Mr. Willis agreed that EPA will have to deal with a number of inventory corr ections and related issues so guidance will be clear when the reset begins. The initial thinking on timing had been to have the reset inventory available for the IUR reporting pe riod, which would mean rolling the program out at the end of 2009 to give the companies time to see wh at is on the inventory and make any necessary corrections. The last mi nute for rollout would be near the start of IUR reporting. EPA seeks guidance on whether to shoot for the beginning of the year for which the IUR data will be compiled, 2010, or to synchronize with the IUR reporting period in 2011.

8Nelson Lawson spoke for the Pine Chemicals Association. The association’s members have hundreds of products on the TSCA invent ory, mostly resins and polymers, and a history of positive interactions with EPA. The association supports the goal of cleaning up the inventory but is concerned about the time requirements. The slowing economy and industry conso lidation have led to reductions in regulatory staff at the same time as the companies are dealing with REACH, and the addition of another program at this time will be burdensome unless it is managed efficiently. The association supports the simple online certification process. The association would prefer a past time limit of five years to three years, since demand for some specialty products fluctuates . The association would like to see the ability to certify a chemical that is expected to become active in the next 12 months and retain it on the active inventory list. The flagging could be worked into the online process, and the product could be automatical ly moved to the inac tive list if EPA does

not receive a notice of commencement within 12 months. He said the active and inactive lists should be available online so they can be scanned for errors, and corrections should be filed online. The correction period should not take more than three to six months. It is important to develop a quick an d cost-effective way of getting chemicals

from the inactive list to the act ive list. He suggested that there be two inactive lists, a fully inactive list for chemicals that would re quire the full PMN process for reactivation and a partially inactive list for a more expedited reactivation process, which would require only a notice of commencement bona fi de and intent to manufacture. Companies that have already gone through the PMN process and paid fees should not have to do so a second time. He further suggested that th e online flagging process allow submitters to point out multiple entries for the same substance for any potential future inventory consolidation or combining of IUR reporting volumes.

Bob Freerksen from DuPont said the proposed ti meline underestimates the burden to industry. The IUR requirements and the reset requirements are not necessarily parallel. Polymers would have to be identified, and there is no volume threshold. The information systems that industry currently has in place for the IUR may not be sufficient for the reset. He added that the upcoming IUR will have an increased requirement for collecting new information on inorganic chemicals. There are also rumors of further changes to the reporting requirements. The current timeline has all these burdens on industry at the same time, and EPA's staff will already be busy with the increase in inquiries from industry. He also expressed concerned about the effect the timing will have on DuPont's suppliers. Many of them are small companies that will have to gear up for the reset. It

will take time for DuPont to make sure the suppliers have certified their products. He said he saw the benefits of timing the rese t with the IUR but that the reasons did not outweigh the increased burden. He agreed that processors should be allowed to certify, that it is consistent with the language of th e statute, and would help processors avoid disruptions in their supply chain.

Bill Herz , Vice President of Scientific Programs for the Fertilizer Institute, said that

brokers and traders have an increased role in commodity chemicals. Manufacturing entities meet 95 to 97 percent of the cost and logistical burden of meeting regulatory

9requirements. He requested that EPA look into how the burden of the IHPV challenge

and other enhancements to TSCA could be mo re equitably shared in order to level the playing field. Mr. Auer agreed that everyone involved in introducing materials into commerce should contribute to developing the in formation. EPA tried to do that with the original HPV challenge. He asked Mr. Herz to submit written comments on the issue.

Mark Duvall from Beveridge and Diamond suggested excluding polymers from the reset inventory, since the EINEC and the USEPA’s IUR do not currently include them. He said that excluding polymers from the TSCA Inventory would be a marked policy shift and would decrease the burden on industry and EPA. Mr. Auer said the scope of data

collection is not under consid eration. The goal is to ge t an understanding of the chemicals manufactured or processed in the US, and that includes polymers. Polymer manufacturers would certify that the pol ymers were manufactured, imported, or processed within the reporting period. Chemicals produced at a rate under 25,000 pounds per year are not currently subject to the indus try update rule, but the information will still be needed to meet the goal. He asked fo r suggestions on how to do it in an efficient manner that protects everyone’s in terests.

Jim Cooper said NPRA appreciated the goals of th e reset and that industry would benefit

from an accurate reflection of the chemicals in commerce. He said that, for the sake of feasibility, separate issues mu st be kept separate, and the reset cannot be confused with longstanding nomenclature issues. He said that he supported certification for the past five years rather than three, since demand does fluctuate. He suggested that chemicals that have already been reviewed could be cl eared more quickly if EPA were to ask if there had been changes in the manufacturing processes or use activ ity scenarios, since that would be the only reas on for further scrutiny. Mark Grenda from Afton Chemical argued that the nomenclature issues have to be corrected. Nomenclature corrections on nonyphenol have been trickling in since th e 1980s. Corrections were much more effective for diisocyanates in the 1990s, wh en the correction procedure was simplified.

He said the nomenclature issue should be addressed by a simplified procedure for

corrections. Mr. Auer agreed but added that nomenclature is often not a simple issue.

Russ White from the American Petroleum Institut e highlighted issues from his written comments, focusing on the reset, IHPVs, and overall ChAMP implementation. On the reset, he encouraged EPA to design a progr am that minimizes burden to industry and EPA as well as disruptions to the marketplace. Because HPV and MPV chemicals are already being prioritized, the re set’s benefits will be small. However, the confusion and burden caused by the reset could be high. He sa id the reset is of a lower priority than other ChAMP components and that slowing the reset timeline would result in a better process and less burden. He asked that EPA publish the list of chem icals to be removed from the inventory in the Federal Register and suggested that EPA provide a period of time during which

substances can be reinstated without penalty and without going through the PMN process. The time period should encompa ss at least one IUR reporting period, which should be a five-year period. He added that any reset efforts should include an exemption

1011 for the petroleum process streams listed under 40 CFR 710, since they are known to be in

commerce and none are obsolete. Regarding IHPVs, he asked for a list of the affected chemicals, which would help stakeholders understand the scope and implica tions of the program. He added that inorganics were characterized under the OECD HPV program, and full use should be made of that data before proceeding with furt her data collection or testing. He supported clustering and asked that EPA provide the re gulated community with ample notice of the Fall 2009 meeting where the cluster approach would be discussed. On ChAMP implementation, he encouraged EPA to include more transparency and clarity in the program to assess and assign risk-based priorities for HPVs and MPVs. To accomplish this, he urged EPA to share information on the document-drafting methodology. Information has been issued on characterizatio n and risk-based prioritization, but he was interested in knowing about the methodology. He asked that EPA produce a list of current MPVs and HPVs. He also asked that EPA publish and give notice of the groups and chemicals that will be assessed similar to the batch notices provided under Canada's chemical manageme nt program. Finall y, he said EPA and industry would greatly benefit from the pla nned user-friendly onlin e repository or docket for each chemical, since it would improve tran sparency and increase site usage. He referred EPA to his written comments for greater detail. Mr. Auer said EPA is nearing

the first release of th e 2006 IUR data, non-CBI database. He said the public should have the information, and he thanked Mr. White for his comments.

ADJOURNMENT

Mr. Auer called for further comments. Heari ng none, he thanked the public for its participation and said OPPT looks forward to working with the public as these projects go forward. He adjourned the meeting at 3:07 p.m.