SBA Advocacy Environmental Roundtable, March 22, 2019

The next U.S. Small Business Administration, Office of Advocacy Environmental Roundtable will meet to discuss the following topics, beginning at 10 a.m. on Friday, March 22, 2019.  The meeting will be held in Washington, D.C., at the Small Business Administration Headquarters, 409 Third Street SW, Eisenhower B Conference Room.  Send your RSVP to  Please indicate whether you are attending in person, or by teleconference.  Information will be sent out to you when you RSVP.  We have adopted a casual attire option for all Roundtable meetings.


10:00 – 11:00 AM             Risk Evaluations Under the Toxic Substance Control Act

Cathy Fehrenbacher, Acting Deputy Director, Risk Assessment Division, Office of Pollution Prevention and Toxics, EPA

11:00 – 12:00 PM              Safe Management of Airbag Waste: Interim Final Rule

Tracy Atagi, Office of Resource Conservation and Recovery, EPA


Roundtable meetings are open to all interested persons, with the exception of the press, in order to facilitate open and frank discussion about the impacts of Federal regulatory activities on small entities.  Agendas and presentations are available to all, including the press.  Anyone who wants to receive roundtable agendas or presentations, or to be included in the distribution list, should forward such requests to  The purpose of these Roundtable meetings is to exchange opinions, facts and information and to obtain the attendees’ individual views and opinions regarding small business concerns.  The meetings are not intended to achieve or communicate any consensus positions of the attendees.

Small Business Environmental Roundtable

Issues for Discussion

March 22, 2019


Risk Evaluations Under the Toxic Substance Control Act

The amended Toxic Substance Control Act (TSCA) requires the Environmental Protection Agency (EPA) to conduct risk evaluations for existing chemicals that the agency has deemed to be high-priority chemicals through its prioritization process. The purpose of risk evaluation is to determine whether a chemical substance presents an unreasonable risk to health or the environment.  If the agency finalizes an unreasonable risk finding, it must manage the risk via regulation of the chemical substance.  This risk evaluation process consists of various components including a scoping document that identifies hazards, exposures, conditions of use, and potentially exposed or susceptible subpopulations to be considered.  The controlling document, however, is a scientific evaluation which includes a hazard assessment, exposure assessment, risk characterization and the risk determination.

Small businesses often lack the time and resources to be able to track and decipher technical scientific documents that may serve as the basis of a potential regulatory restriction on their use of a chemical substance.  To facilitate a better understanding of the risk evaluations, EPA will provide an overview of its process and its components.

RCRA and the Airbag Waste Interim Final Rule

EPA’s recent actions related to the management of airbag waste has revived curiosity with the agency’s approach to general hazardous waste exclusions under the Resource Recovery and Conservation Act (RCRA).  On November 30, 2018, EPA published an interim final rule to address the ongoing Takata airbag recalls by facilitating the removal and disposal of the airbag waste.  The agency provided a conditional exemption from its hazardous waste regulations under RCRA for collection of recalled airbag wastes.  The exemption will prevent those involved in removing or replacing the airbags from being moved into a category of larger waste generation  which would trigger additional requirements.  Even though the agency took public comments on the interim final rule, it became effective immediately.  EPA will be providing an overview of RCRA and examples of adjustments made to address various wastestreams including the airbag waste interim rule.