SBA Environmental Roundtable Meeting – December 18, 2020
FRIDAY, December 18, 10 a.m. – noon.
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, December 18, 2020. The meeting will be held using the Microsoft Teams platform.
Send your RSVP to firstname.lastname@example.org. A meeting link will be provided to you when you RSVP.
10:00 AM – 10:20 AM Introductions and Update on Chemicals Designated as High Priority under TSCA
Dave Rostker, SBA Office of Advocacy
10:20 AM – 11:20 AM EPA’s Final Risk Evaluation for Trichloroethylene (TCE)
Katie McNamara, Office of Pollution Prevention and Toxics, EPA
The Impact of the TCE Risk Evaluation on Small Business
Christopher Bevan, Director of Scientific Programs, HSIA
11:20 AM – 12:00 PM EPA’s Draft Scope of Risk Evaluations for DIDP and DINP
Collin Beachum, Jennifer Brennan and John Allran, 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 email@example.com. 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
December 18, 2020
EPA recently published its final risk evaluation for the fifth of its 10 high-priority chemicals under the amended Toxic Substance Control Act (TSCA). EPA completed the final risk evaluation for trichloroethylene (TCE) in November 2020. After evaluating 54 conditions of use of TCE, EPA has determined that TCE presents an unreasonable risk under 52 conditions of use. This includes an unreasonable risk to workers and occupational nonusers (ONUs) when manufacturing the chemical; processing the chemical for a variety of uses; when used in a variety of industrial and commercial applications; and disposal. This also includes an unreasonable risk to consumers and bystanders from most consumer uses. TCE does not pose an unreasonable risk under distribution in commerce or in consumer use in pepper spray. EPA also determined that TCE does not present an unreasonable risk to the environment under all conditions of use. 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.
Christopher Bevan is the Director of Scientific Programs at the Halogenated Solvents Industry Alliance, Inc. (HSIA). He is a toxicologist with over 30 years of experience in risk assessment and product safety. In discussing EPA’s final risk evaluation for methylene chloride, Dr. Bevan will cover education, warnings, training, data gaps, etc. and the lack of understanding of what small business needs to do. HSIA represents producers and users of methylene chloride. Many of HSIA’s user members include small businesses. In the past, HSIA has participated in a small business advocacy review panel for methylene chloride to assist small entity representatives in providing advice and recommendation to EPA on its potential regulation for the use of this chemical as a paint remover.
EPA’s Draft Scope of the Risk Evaluations for DIDP and DINP
DIDP and DINP are common chemical names for categories of chemicals primarily used as plasticizers in plastic and rubber products. In 2019, manufacturers requested EPA conduct a risk evaluation for these chemicals. As a first step toward those risk evaluations, on November 27, 2020, EPA published a draft scope, which include the hazards, exposures, conditions of use, and the potentially exposed or susceptible subpopulations EPA expects the risk evaluations will cover. 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. Comments on these draft scopes are due on January 11, 2021.