What I'm going to talk about today in the industrial chemical space with the passage of the Lottonberg Act is first I'm going to spend about half an hour going over some of the key changes that the law brought to us and they are significant. So now we have a mandatory duty to prioritize and assess those chemicals for safety. And we have to do that against a risk-based standard. If the EPA does identify an unreasonable risk associated with its evaluation of an existing chemical substance, it must then move directly to regulatory action to address those risks. And that's where cost benefit, balancing, impact on the economy, substitutes, etc. come into play. Finally, for this slide, an expanded authority to acquire information on chemicals. The first thing we have to do is do a prioritization exercise to take those existing substances, those thousands of however many there are and I'll get to that in a minute and come up with a process for prioritizing them to identify which substances might be high and low for risk evaluation. If we identify a chemical as a high priority for risk evaluation, we must move directly then to conduct that risk evaluation. We have three years to do it. One starting point is to fulfill another provision of the law which is to identify an active inventory of chemical substances. So whatever that number is of active substances, that becomes the universe on which we'll do this prioritization exercise to identify those chemicals that will be candidates for risk evaluation. A risk evaluation means more than just an assessment of the risk. It also means a determination about whether that chemical presents an unreasonable risk for the conditions of use of that chemical. Now the law requires us to do evaluations on the conditions of use and generally speaking, we believe that that means most if not all of the identifiable uses of that chemical substance. Then three and a half years we have to be able to do in 20 substances a year for risk evaluation and as we complete one, another one needs to come into the program through that prioritization process that I mentioned. All of these issues related to conditions of use, unreasonable risk, reasonably available information to connect to risk evaluation. There's a lot of discussion going on with what those terms mean and how they would affect an evaluation of an existing chemical. A lot of this is going to play out in the doing obviously and these first 10 I think will be our proving ground as to how we work with those concepts articulated in the law. How we work reasonableness into the evaluation to make the determination based solely on the assessment and risk based criteria is something that we're all going to have to work through. Certainly we have benchmarks that we've used for decades for risk, cancer and non-cancer. So we'll have to work these out through the first 10. But if in those first 10 should we identify risk of concern, then we'll have to move right to risk management and those cost factors will begin to come into play in how we address those risks. We've got two years to do risk management action after I haven't identified those risks in the evaluation. The work plan isn't the only place that is a source of chemicals for risk evaluation. Chemical manufacturers can request a risk evaluation of a chemical as well. If that chemical is one of the work plan chemicals, then the law says that the manufacturer should pay half of the cost of the risk evaluation. If it's not on the work plan, they pay the full cost. For new chemicals, the changes were equally profound in that now for a new chemical substance during our pre-manufacture review, we must make an affirmative determination as to whether that chemical substance presents an unreasonable risk. I've outlined here where essentially for considerations that or determinations that the agency might make for a new substance during that 90 day review that we have for pre-manufacture notices. The first is the will present. If we have information that suggests that the chemical substance will present an unreasonable risk, we would move right to an order and a five F of the statute to address it. That's actually something that's not new. What is new is the second bullet here where it says, if information is insufficient to make a finding, do a reason evaluation of the risk of substance, we would then issue an order under Section 5E to basically state that if the company wants to commercialize this substance, then we're going to need additional information prior to commercialization. Make a finding of may present unreasonable risk. We made this previously. What's changed though now is that under the new law, we would make a determination for known and reasonably foreseen uses. That means to us, as we're interpreting the law now, is that the known uses are in the pre-manufactured notice. The company says we intend to commercialize this substance for these uses, those two us are the known uses. The reasonably foreseen uses, as we're interpreting that now, is if there are uses associated with a close analog to this chemical, a chemical that seems to be one that's closely related and could likely be used in the same way as the PMN substance, and there are uses there that are not on the PMN form, then we would have to make our determination not only on the uses that are in the PMN form, but also on those reasonably foreseen uses. And finally, there's the finding of not likely to present unreasonable risk. Finding not likely doesn't say safe, but it's with the language it was in the law. And basically for us, that means if a substance is not likely to present, then the company is good to go to manufacture per the PMN form with no restrictions. Making that affirmative finding is a big change. The law now requires that companies substantiate their CBI claims. The law allows us to partially offset the cost of implementing the law with a fees provision to up to 25 million in annual user fees to support the program. There was a special provision in the law for persistent bio-cumuluvant toxic chemicals. And it was very specific. It said, look at the existing TOSCA work plan. Identify those chemicals that ranked high for persistence and bio-cumulation and toxicity. Set aside the metals. Set aside those chemicals where you're taking other action under other sections of the law, like section five. Set aside those for which you've already started problem formulation. Well, that left us with seven chemical substances. Basically, the law implied that given that they were PBTs, essentially the risk case had been made and it was really incumbent on the agency to take exposure reduction actions against them. The law did say, though, that EPA, you've got to stick to your timeframes as mandated by the law and you can't pause the state forever. So should we not meet our deadline, then that state pause is lifted.