SBA Environmental Roundtable Meeting – October 16, 2020

FRIDAY, October 16, 2020, 10 a.m. – 11 a.m.

Via Microsoft Teams Meeting

The next U.S. Small Business Administration, Office of Advocacy Environmental Roundtable will meet virtually to discuss the following topics, beginning at 10 a.m. on Friday, October 16, 2020.  The meeting will be held using the Microsoft Teams platform.

Send your RSVP to  A meeting link will be provided to you when you RSVP.


10:00 AM – 11:00 AM      EPA’s Final Risk Evaluation for Cyclic Aliphatic Bromide Cluster (HBCD)

Sue Slotnick, Office of Pollution Prevention and Toxics, 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

EPA’s Final Risk Evaluations for Cyclic Aliphatic Bromide Cluster


EPA recently published its final risk evaluation for the third of its 10 high-priority chemicals under the amended Toxic Substance Control Act (TSCA).  On September 25, 2020 EPA published a risk evaluation for HBCD, finalizing determinations of unreasonable risk for 6 out of 12 evaluated conditions of uses.  EPA found the import, processing, recycling, commercial use, consumer use, and disposal of HBCD present unreasonable risks to the environment and the use of HBCD in building and construction materials and exposure through demolition present an unreasonable risk to workers and occupational non-users. A final determination that a condition of use presents an unreasonable risk of injury to health or the environment means that the agency will have to regulate those risks, which can include use-restrictions or bans, among other options.

The agency is currently in the process of developing ways to address the identified unreasonable risks and has up to one year to propose and take public comments on any risk management actions.  Within this time frame, the agency will also have to consider whether any potential regulations for the identified risks will have a significant economic impact on a substantial number of small entities and if so, the agency will need to convene a small business advocacy review panel to seek advice and recommendations from representatives of affected small entities on the potential impact of the proposed rule.  For this reason, it is important for small business stakeholders to be informed of the conditions of use that have been determined to pose an unreasonable risk and the basis for those determinations.  At this roundtable, EPA will be providing an overview of this final risk evaluation, with time for discussion and questions.  

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