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Kathleen M. Roberts [kroberts@lawbc.com] 10/31/2017 1:01:49 AM Morris, Jeff [/o=ExchangeLabs/ou=Exchange Adm inistrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=55c34872e6ea40cab78be910aec63321-Morris/ Jeff] lbergeson@lawbc.com [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=9530e97746d74c8484fd5469fbf432el-lbergeson@ lawbc.com]; Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy]; Mclean, Kevin [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=869a9152d655420594d8f94a966b8892-KMCLEAN]; Grant, Brian [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=ec6104b72cab42ba9blelda67d4288ae-Grant, Brian] New Chemicals Coalition - Letter to EPA on Section 5 Points to Consider Document 00223603.pdf
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Jeff:
Appended is a letter from the New Chemicals Coalition (NCC), a group of over 20 company representatives that have come together to identify new chemical notification issues under the amended Toxic Substances Control Act (TSCA) and to work collaboratively with you and your team to address them.
Our letter focuses on the anticipated U.S. Environmental Protection Agency (EPA) updated guidance material to assist stakeholders in developing Section 5 submissions and provides specific issues that must be included in that guidance so it is truly helpful to the regulated community. As noted in our letter, beyond knowing what to report in a submission, stakeholders need to understand why the information is needed by EPA assessors and how that information will be used by EPA and incorporated into a new chemical risk evaluation. Without this information, the lack of certainty regarding the EPA process will adversely impact investment, stifle innovation, and deny the regulated community with a clearer understanding of how EPA is actually implementing the new law as it relates to new chemical review.
We will be in touch with you later this week to discuss the letter and potentially arrange for a meeting with you and other EPA staff.
KATHLEEN M. ROBERTS
VICE PRESIDENT, B&C CONSORTIA MANAGEMENT, L.L.C,
B E R G E S O N & C A M P B E L L PC
2200 Peimsylvaiiia Avenue, iSi.W, Suite 100W j Washington, D,C. 20037
T: 443-964-4653 | F: 202-557-3836 | 1awbc.com
Sierra Club v. EPA 18cv3472 NDCA
Tier 12
ED 002061 00040817-00001