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June
25,
2001
~
y
BAND
DELWERY
TheHonorable
Christine
T.
Whitman
Administrator,
U.
S.
Environmental
Protection
Agency
Axiel
RiosBuilding
1200
Pennsylvania
Avenue,
NW
WashingtonDC
20460
RE:
OPPTS­
002741)~
Voluxtta~
yChildrcn's
Chemical
Evaluation
Pro~
ra~
n
VCCEP
Sponsorsbi~
CommitmentfotEthylene
Dichloxide
(
CAS
No,
I07­
0~
J
Dear
Administrator
Whitman;

TheAmerica
Chemistry
Council
Vinyl
Chloride
Health
Committee,
on
behalf
of
the
companies
identified
below
which
manufacture
ethylene
dichioride
(
EDC)
commits
to
sponsor
EDC
in
Tier
I
ofthe
pilot
Voluntary
Children's
Chemical
Evaluation
Program
(
VCCEP).
65
Fed.
Reg.
81700­
718
(
Dec.
26,
2000).

rn
njsithig
this
commitment,
the
Health
Committee
is
acting
voluntarily
and
not
in
response
to
any
legally
enforceable
mandate.
The
Health
Com~
mitteealso
emphasizes
that
EPA
has
recognized
that
identification
of
EDC
in
the
VCCEP
pilot
"
does
not
mean
that
EPA
has
made
or
will
make
~
adetermination
that
any
uses
of
the
chemical
pose
significant
risks
to
children's
health,"
and
that
"
EPA
may
ultimately
determine
that
reasonably
anticipated
exposures
and
risks
from
expected
uses
do
not
pose
any
unique
or
other
concerns
for
children's
health
and
safety"
(
65
Fed.
Reg.
81702).

°
The
EDC
producers,
through
the
Health
Committee,
intend
to
fulfill
this
commitrnentby
executhg
and
implementing
(
through
the
HAP
Task
Force)
an
Enforceable
Consent
~
greement
(
ECA)
`
pursuant
to
which
they
agree
to
conduct
specified
toxicity
testing
in
lieu
of
testing
pursuant
to
the
hazardous
air
pollutants
test
rule
àriginally
propoaed
by
EPA
in
1996.
These
studies
will
providó
new
information
relevant
to
an
evaluation
of
the
toxicity
of
EDC.
It
is
intended
that
this
ECA
would
be
signed
by
HAP
Task
Force
participants
and
the
U.
S.
Environmental
Protection
Agency
(
EPA)
within
six
months
of
the
date
of
this
letter.
The
start
dates
for
the
toxicity
testingand
submission
dates
for
the
final
reports
shall
be
as
specified
in
the
ECA.

The
Health
Committee
commits
to
develop
a
hazard
assessment
of
Tier
1
and
existing
higher­
tier
studies
(
including
the
studies
to
be
conducted
under
the
ECA),
Tn
addition,
the
Health
Committee
commits
to
develop
an
exposure
assessment
that
meets
or
exceed~
the
~
r
R~
pcnsI~
iIe
Care'

300
W~
SOfl~
ou~
evard,
ArlIngton,
VA
22209
Tht
703­
741­
5600
Fax
703­
741.6091
http://
www.
amerIcartchemlstry.
com
RECEIVED
OPPT
NCIC
2003
MAR11
5:
03PM
OPPT­
2003­
0010­
0040
f~),

Christine
T.
Whitman
June25,
2001
Page
2
requirements
for
a
Tier
I
Exposure
Assessment
specified
by
EPA
(
65
Fed.
Reg.
81711).
The
Health
Committee
fttrther
commits
to
develop
a
risk
assessment
which
integrates
these
hazard
and
exposure
assessments
and
characterizes
the
potential
risks
to
children
posed
by
EDC
based
on
the
quality
and
extent
of
the
available
data.
The
Health
Committee
will
also
prepare
a
data
needs
assessment
that
includes
a
weight­
of­
the­
evidence
evaluation
of
the
available
hazard
and
exposure
information
and
assesses
whether
additional
information
is
needed
in
order
to
evaluate
the
potential
risk
to
children.
These
will
be
prepared
and
submitted
in
a
timely
fashion
following
completion
oftheECA
testing.

Finally,
the
Health
Committee
will
prepare
a
Peer
Consultation
Document
consisting
of
the
four
components
identified
above
and
will
provide
three
bard
copies
and
an
electronic
copy
to
EPA.
We
understand
that
EPA
will
make
the
Document
available
to
a
third­
party
scientific
organization
which
will
distribute
it
to
the
Peer
Consultation
Group
and
present
the
assessments
and
recommendations
to
the
Group.
It
is
anticipated
that
the
Peer
Consultation
will
result
in
a
report
to
EPA
(
to
be
prepared
by
the
third­
party
contractor)
which
will
include
a
recommendation
as
to
whether
further
testing
or
evaluation
ofEDC
under
the
VCCEP
is
or
is
not
necessary,

As
part
of
the
foregoing
activities,
the
Health
Committee
commits
(
i)
to
judge
existing
studies
not
conducted
under
Good
Laboratory
Practices
(
GLP)
guidelines
based
on
their
merits,
(
ii)
to
generate
any
new
hazard
data
under
GLPs
and
current
EPA
test
guidelines
as
ofthe
date
the
testing
is
initiated,
and
(
iii)
to~
make
the
hazard
and
exposure
data
developed
publicly
available.
Should
elements
of
the
VCCEP
pilot
change
in
the
ftture,
the
Health
Committee
reserves
the
right
to
adjust
its
commitment
accordingly.

We
trust
that
this
letter
is
sufficient
to
express
our
commitment
to
sponsor
EDC
in
the
first
tier
of
the
VCCEP
pilot.
This
commitment
is
made
on
behalf
of
the
following
EDC
producers:

Formosa
Plastics
Corporation,
U.
S.
A.
Poly
One
Corporation
Georgia
Gulf
Corporation
PPG
Industries,
Inc
Occidental
Chemical
Corporation
The
Dow
Chemical
Company
Oxy
Vinyls,
LP
Vulcan
Materials
Company
If,
for
any
reason,
this
voluntary
initiative
should
not
be
undertaken
by
the
Health
Committee,
then
any
commitment
will
devolve
to
the
foregoing
companies.
C~
LJ'
CJC)
O
Clthstine
T.
Whitman
June
25,
2001
Page3
The
technical
contact
for
the
Health
Committee
is
as
follows:

Wendy
K.
Sherman
Manager,
Vinyl
Chloride
Health
Committee
American
Chemistry
Council
1300
Wilson
Boulevard
Arlington,
Virginia
22209
(
703)
741­
5639
(
Phone)
(
703)
741­
6091
(
Fax)
wendysherman@
anieiicanchemistry.
corn
Please
do
not
hesitate
to
contact
us
if
there
are
anyquestions
about
this
commitment.

Si
cerely
yours,

°
Courtney
M.
Price
°
Vice
President,
CHBMSTAR
cc:
Charles
Auer,
Director
Chemical
Control
Division
Office
ofPollution
Prevention
and
Toxics
Steve
Johnson,
Assistant
Administrator
Office
ofPrevention,
Pesticides
and
Toxic
Substances
Richard
W.
LCUkrOth
Peter
E.
Voytek,
Ph.
D.
Caffey
Norman
VCHC
Consortia
Members
TOTflL
P.~
OE~
