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broader stakeholder community and EPA itself greater certainty about what
EPA must rely upon in making prioritization designations
Codifying these requirements in the rule will assure consistency in EPA's prioritization
decisions
All of the above will enhance the credibility of EPA's prioritization decisions.
B. EPA requests comments on its proposed process for prioritization overall.
Response: First, EPA relies heavily upon the "pre-prioritization" step in the process rule, but
provides very little detail about how it would function. As recommended above, EPA must clarify
this step and should publish a notice with more details and seek public comments on it before
finalizing this rule. Alternatively, EPA should propose and finalize a supplemental rule to provide
the necessary level of detail before EPA's first application of the prioritization process.
Second, EPA's process for prioritization overall seems resigned to codifying a "slow road" to
prioritization by a) ignoring the value of low priority designations; and b) lining up high priority
chemicals to wait for what EPA envisions as a slow risk evaluation throughput. EPA's prioritization
process, in other words, lacks vision for the potential future throughput of the program. The role of
215 century tools will help the Agency both prioritize chemicals and evaluate the risks of high
priority chemicals, consistent with Congress's intent that the Agency make timely decisions.
C. Public input at pre-prioritization step
EPA requests comment on whether and how EPA should solicit additional input at the pre-
prioritization phase." Response: It is not only appropriate, but well advised for EPA to solicit public
input at each stage of the prioritization process. From a "data quality" perspective it is important for
the public to have the opportunity to comment on the data/information that EPA believes is relevant
to prioritization of chemicals for risk evaluation. As discussed in our comments above, ACC
believes EPA must take a sequenced, step-wise approach to gathering available information and/or
developing new information in the pre- prioritization stage. It makes sense for EPA to first gather
reasonably available information, then solicit public input to identify additional data/information
from stakeholders, on a voluntary basis. Then EPA should use reporting tools under Section 8 for
additional existing information if needed. Only after using these approaches should the Agency
consider ordering the development of new information for prioritization purposes, subject to the
requirements of LCSA Section 4.
D. Consideration of substitutes in pre-prioritization
EPA asks "whether and how information on the availability of chemical substitutes should be
taken into account during this phase [pre-prioritization] of the prioritization process". Response:
Substitutes are not relevant to and should not be considered in the prioritization process. Both the
LCSA and EPA's proposed prioritization process rule (at 702.1 1(b)) make clear that EPA cannot
consider "non-risk factors" as part of prioritization. The availability of "substitutes" is a "non-risk
factor." Alternatives can certainly be taken into account in the risk management stage, after the risk
evaluation, but do not have a role in the prioritization process.
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Source: https://www.industrydocuments.ucsf.edu/docs/jzbn0226

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