There is a good chance that another company will volunteer to perform the testing, and there may be little chance that the larger company will find it worth its effort to attempt to collect your company's small share of the costs. You should consider whether your company can form a consortium with other manufacturers to reduce the costs of testing and make volunteering more attractive. One of the main benefits of volunteering is that you can group chemicals in categories. This may significantly reduce the amount of testing. Therefore, once you determine how many of your chemicals are on the HPV chemical list, one of the first things you should do is determine whether any of your chemicals can be grouped into categories.
Categories can include non-HPV chemicals.
Moreover, you should consider whether there may be chemicals manufactured by other producers which may be able to be grouped into a category. Depending on how many chemicals a company is able to group together, the cost savings may be sufficient to justify participating in the voluntary program. Such a large grouping, if not challenged by EPA, could result in significant cost savings. Under a test rule, a company will have to submit the full study report to EPA, where it will be made publicly available, and could be used by competitors to meet data requirements in other countries. One of the benefits of the program that EPA has highlighted is that under the voluntary program, there will be more time for testing.