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{00620.002 / 111 / 00146326.DOC 2}

2200 Pennsylvania Ave, N.W. Suite 100W (202) 833

- 6580 Washington, D.C. 20037 www.braginfo.org November 5, 2014

Via Federal Express

OPPT CDR Submission Coordinator

Mailcode: 7407M Office of Chemical Safety and Pollution Prevention U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460

Re: Petition for Parti al Exemption of Biodiesel Products

Dear Sir or Madam:

The Biobased and Renewable Products Advocacy Group (BRAG ® ) 1 submits this letter as a supplement to its October 21, 2014, petition to amend the Chemical Data Reporting (CDR) partially exempted chemical list at 40 C.F.R. Section 711.6(b)(2)(iv). Specifically, BRAG wishes to amend the list of chemicals to be considered in the proposed “biodiesel” chemical category for partial exemption to include:

 Canola Oil, Methyl Ester: Chemical Abstracts Service Re gistry Number (CASRN) 129828

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Petition Elements

As identified in 40 C.F.R. Section 711.6(b)(2)(ii), the U.S. Environmental Protection Agency (EPA) is required to consider the following information in determining whether a partial exemption should app ly:

(A) Whether the chemical substance qualifies or has qualified in past [Inventory Update Reporting] collections for the reporting of the information described in § 711.15(b)(4).

1 BRAG provides a platform for organizations engaged in biobased chemistries to identify regulatory barriers for their unique products and to work collectively to address them.

BR AG tackles regulatory hindrances related to commercialization of biobased products and works to improve public awareness of the benefits of these products.OPPT CDR Submission Coordinator November 5, 2014 Page 2

{00620.002 / 111 / 00146326.DOC 2} (B) The chemical substance’s chemical and physical properties or potential for p ersistence, bioaccumulation, health effects, or environmental effects (considered independently or together).

(C) The information needs of EPA, other Federal agencies, Tribes, States, and local governments, as well as members of the public.

(D) The availabilit y of other complementary risk screening

information.

(E) The availability of comparable processing and use

information.

(F) Whether the potential risks of the chemical substance are adequately managed.

Information on Canola Oil, Methyl Ester, CASRN 129828

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- 6, for each of these considerations is provided below.

Qualification for Previous CDR Reporting

Based on information derived from the EPA Chemical Data Access Tool (CDAT,

available at http://java. epa.gov/oppt_chemical_search/ ), Canola Oil, Methyl Ester, CASRN

129828

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- 6 qualified for reporting under the 2012 CDR. The reported national production volume was withheld, with two companies reporting.

Physical/Chemical Properties and Health/Environ mental Effects

Petitioners are not advocating that the subject chemical for this amendment or the original chemicals listed in the October 21, 2014, petition are non

- hazardous or non

- toxic. Because of the nature of the chemicals and potential toxicity co ncerns, specific exposure controls and worker protections are in place to minimize potential releases. Because similar exposure controls and worker protection approaches were sufficient for EPA to determine petroleum process streams in 40 C.F.R. Section 7 11.6(b)(1), referred to as the (b)(1) List, should receive partial reporting exemptions, the same rationale for partial reporting exemption should be applied to the chemicals listed in this petition.OPPT CDR Submission Coordinator November 5, 2014 Page 3

{00620.002 / 111 / 00146326.DOC 2} A compilation of available information related to the p hysical and chemical properties and health and environmental effects derived from registration dossiers for the European Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program and other publicly available sources is provided i n Appendix 1, which was also included in the initial October 21, 2014, petition.

Information Needs of EPA, Other Agencies, and Public

With the ongoing government dialogue concerning biofuels, including biodiesel, there is and will continue to be signif icant interest in biodiesel substances and this level of interest will result in identification of information needs. Nonetheless, the screening level process and use information collected under CDR will likely be of little use within this debate. Moreov er, information can and is being collected under other programs. ( See Availability of Comparable Processing and Use Information below.)

Availability of Complementary Risk Screening Information

EPA has access to risk screening information for Canola Oil, Methyl Ester, CASRN

129828

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- 6 through the Section 5 new chemical review conducted on this substance.

Availability of Comparable Processing and Use Information

The collection of information on processing and use of biodiesel under CDR is not

necessary for EPA, other agencies, or the general public, as relevant information collection and reporting already occurs under other federal programs. Information on the production and use of biodiesel is currently collected, maintained, and publicly reported by t he U.S. Energy Information Administration (EIA). EIA issues a monthly biodiesel production report that provides data on the U.S. biodiesel industry, including plant locations, production volumes, and sales of biodiesel to end

- users. There are also other reports on biofuels, including biodiesel, generated by EPA and the U.S. Department of Agriculture (USDA).

Management of Potential Risks

The manufacture and processing of Canola Oil, Methyl Ester, CASRN 129828

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and the other substances on the initia l petition uses continuous closed systems, and regulations require transport and storage to occur in well

- controlled vessels. These process controls to reduce potential for releases and exposures are similar to those implemented for the petroleum process streams on the (b)(1) List, for which EPA determined full CDR reporting was not warranted.OPPT CDR Submission Coordinator November 5, 2014 Page 4

{00620.002 / 111 / 00146326.DOC 2} Thank you for the opportunity to provide this supplement to the BRAG October 21, 2014, petition. BRAG members look forward to the opportunity to respond to an y questions that EPA may have regarding this petition and to EPA’s response to the petition request. Please call me at 443

- 964

- 4653 or e

- mail me at kroberts@bc

- cm.com for further information or to schedule a meeti ng.

Sincerely,

Kathleen M. Roberts

BRAG Executive Director

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