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comment periods are needed to ensure stakeholder engagement and robust well-supported
results.
A.
Comment Period on the Draft Scope
ACC recommends that EPA allow a period of 60 calendar days for commenting on the draft
scope. EPA's proposal of 30 calendar days is far too short to allow for sufficient evaluation of
hazard information, exposure information, and planned methods.
For organizations like ACC, time is needed not only for staff to review the draft document, but
also to ensure coordination with multiple member companies who will be potentially be
impacted by the forthcoming risk evaluation. Time is needed to ensure that comments developed
are not only representative, but also constructive and informative to EPA. A 30-day comment
period is simply unworkable, particularly if EPA intends to include all conditions of use. EPA
will likely also rely on pre-existing evaluations to inform screening level evaluations and a
detailed review of this underlying information will take time. As draft scope documents will
likely be complex, ACC recommends that the default comment period be 60 calendar days and
that extensions of the comment period be allowed only for particularly complex scoping
assessments.
B.
Comment Period on the Draft Risk Evaluation
Once the scoping evaluation is complete, EPA will likely spend two years conducting the risk
evaluation. When the draft risk evaluation is complete, EPA proposes a 30 day calendar period
for public comments. ACC recommends that this comment period be at least 90 calendar days.
The draft risk evaluation is expected to be a complex, science and data rich evaluation that is the
culmination of over two years of work by EPA staff and contractors.
This evaluation will likely also consider multiple populations, including susceptible populations
such as workers, and multiple exposure scenarios for each individual condition of use. The
document may be made more complex by the fact that EPA may be evaluating multiple
conditions of use and, as required by the LCSA, will include a detailed and transparent weight of
the evidence evaluation of hazard and exposure information for each condition of use. The data
and calculations presented in the document will also need to be scrutinized, and modeling results
independently verified. This document will be far more complex than the scoping evaluation and
sufficient time will be needed to review, coordinate, and prepare constructive comments for
EPA.
EPA must ensure that this public comment period occurs before the draft risk evaluation
undergoes peer review as the peer reviewers should be informed by the public comments. In
addition, when EPA releases the draft risk evaluation, a draft charge for the peer reviewers
should also be released and made available for public comment. The final charge sent to peer
reviewers should be informed by and revised, as needed, following public comment on the draft
to ensure that the peer review will address areas where there is significant stakeholder
disagreement. This approach is consistent with the EPA SAB staff commitment to ensuring that
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Source: https://www.industrydocuments.ucsf.edu/docs/kzbn0226

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