Comments
by
Participants
in
the
Public
Meeting
on
the
Draft
Instruction
Manual
for
the
2006
Updating
of
the
TSCA
Chemical
Substance
Inventory
Meeting
Held
on
August
1,
2003
A
public
meeting
was
held
by
the
Economics,
Exposure,
and
Technology
Division
of
EPA's
Office
of
Pollution
Prevention
and
Toxics
on
August
1,
2003
to
receive
comments
on
the
clarity,
comprehensiveness,
and
utility
of
the
draft
Instruction
Manual
for
the
2006
Partial
Updating
of
the
TSCA
Chemical
Inventory
Database.
The
draft
Instruction
Manual
details
how
to
respond
to
the
information
collection
requirements
of
the
Inventory
Update
Rule,
40
CFR
Part
710,
which
was
substantially
modified
by
amendments
promulgated
on
January
7,
2003.
Thirtyfive
persons
representing
industry
and
trade
groups,
the
entities
affected
by
the
regulation,
attended
the
meeting
which
commenced
at
9:
00
a.
m.
and
ended
at
2:
20
p.
m.
and
was
held
in
Room
4225
of
EPA­
East.
In
addition
to
comments
received
at
the
meeting,
many
participants
agreed
to
submit
detailed
written
comments
which
will
be
helpful
to
EPA
staff
in
revising
the
draft
Instructions
and
preparing
guidance
to
respond
to
the
questions
and
concerns
of
individuals
responding
to
the
requirements
of
the
amended
Inventory
Update
Rule.
The
Environmental
Assistance
Division
contributed
to
outreach
efforts
prior
to
the
public
meeting
and
assisted
in
the
arrangements
for
the
meeting.
Tabulated
below
are
the
comments
received
from
attendees
about
the
draft
Instruction
Manual.

Overall
1.
Give
industry
a
schedule
of
when
to
submit
written
comments
on
the
Instruction
Manual
and
a
method
to
determine
when/
if
the
comments
will
be
addressed
by
EPA.

Chapter
1:
Introduction
1.
Introduction
section
is
important.
Be
more
specific
on
how
the
information
will
be
used.
More
explicit
use
information
may
help
submitters
decide
level
of
effort
needed,
esp.
to
collect
processing
and
use
information.

2.
It
would
be
useful
to
know
historical
context
of
how
the
information
will
be
used.
For
example,
information
about
3,000
chemicals
is
already
being
collected
by
EPA.
Has
EPA
reviewed
these
chemicals
in
depth?

3.
Define
how
the
reporting
requirements
are
similar
or
different
from
TRI
reporting
requirements.
For
example,
are
the
definitions
of
`
readily
obtainable'
and
`
reasonably
ascertainable'
consistent
with
TRI?
Or
with
other
regulations?

4.
State
the
definitions
of
`
readily
obtainable'
and
`
reasonably
ascertainable'
up
front
in
Chapter
1.
August
1,
2003
Focus
Meeting
Comments
Page
2
Chapter
2:
Reporting
Requirements
and
Chapter
3:
When
to
Report
1.
Section
2.1
­
Originally,
some
byproducts
and
mixtures
were
listed
on
the
TSCA
Inventory.
Are
these
substances
reportable?

2.
There
are
many
inorganic
compounds
not
on
the
TSCA
Inventory.
Are
these
compounds
reportable
under
IUR?
Are
there
examples
of
inorganics
that
are
not
on
the
Inventory?
EPA
requested
the
commenter
send
in
specific
examples.

3.
Does
the
IUR
capture
the
streams
on
the
1995
statutory
mixture
policy?
Commenter
will
provide
EPA
with
examples.

4.
Does
EPA
intend
to
capture
information
about
solid
solutions
under
the
IUR
rule?
Please
provide
additional
guidance
on
this
topic.

5.
The
list
of
petroleum
streams
that
are
partially
exempt
is
from
the
1982
inventory.
Additional
streams
should
be
added
to
the
list.
The
commenter
will
provide
EPA
with
an
updated
list.

6.
If
a
new
petroleum
process
stream
is
created,
how
do
we
add
it
to
the
partially
exempt
petroleum
process
streams
list?

7.
The
first
decision
point
on
Figure
2­
1
asks
if
the
chemical
is
on
the
Inventory.
If
it
is
not,
Figure
2­
1
shows
that
you
do
not
need
to
report.
However,
it
may
not
be
so
simple.
More
information
or
a
more
complex
flow
diagram
should
be
provided
to
clarify
this
topic.

8.
Expand
definition
of
by­
product
and
clarify
what
is
meant
by
commercial
advantage.
Using
the
term
`
no
commercial
value'
is
different
from
the
definition
of
manufacture,
which
uses
the
term
`
commercial
advantage.'

9.
Improve
instructions
for
importers,
specifically
importers
of
mixtures.
For
example,
how
do
you
report
a
paint
made
of
many
substances.
It
would
help
to
have
a
decision
logic
diagram
for
importers.

10.
Provide
a
better
definition
for
the
site
of
import.
Additional
commenters
stated
there
should
be
more
instructions
for
importers.

11.
A
person
attending
the
meeting
commented
that
importers
sell
directly
to
users,
but
don't
report.
There
is
confusion
as
to
who
is
responsible
for
reporting.
August
1,
2003
Focus
Meeting
Comments
Page
3
12.
Another
person
asked
a
specific
question
about
identifying
the
site
of
import
for
pipelines.

13.
Section
2.2.2
states
you
must
report
for
sites
you
owned
or
controlled.
What
is
the
definition
of
`
controlled'?
Who
completes
the
form
if
a
chemical
is
manufactured
by
a
joint
venture
or
toll
manufacturer
or
a
contractor
under
control
of
a
another
company?

14.
Definitions
of
small
business
varies
from
other
government
regulations,
such
as
EPCRA,
OSHA
(
ag
retailers).
Point
out
the
differences
in
definitions
for
small
businesses
that
may
be
used
to
other
requirements.

15.
Clarify
definition
of
manufacture
to
export.

16.
Clarify
definition
of
non­
isolated
intermediate.
Can
a
non­
isolated
intermediate
be
used
in
more
that
one
vessel,
such
as
2
vessels
connected
by
a
pipe?

17.
More
complex
examples
are
needed
to
illustrate
each
point.

18.
Provide
more
details
on
the
partial
exemption
and
the
process
for
change.

19.
Incorporate
CFR
references
into
Figure
2­
1.

20.
Use
more
visuals
such
as
the
flow
diagrams,
especially
the
example
diagrams,
used
in
the
presentation
in
the
Instruction
Manual.

21.
Be
clear
and
consistent
on
reporting
requirement
of
25,000
pounds
or
more.
Is
it
greater
than
25,000
pounds
or
greater
than
or
equal
to
25,000
pounds?

22.
The
first
paragraph
in
Section
2.2.2
states
you
must
report
if
you
manufactured
25,000
pounds
or
more
at
any
given
time
during
calendar
year
2005.
Rephrase
this
sentence
since
EPA
is
looking
for
the
aggregate
production
for
the
year.

23.
How
do
you
report
if
there
was
a
change
in
company
ownership
during
the
reporting
year?

24.
Can
the
PMN
reportability
language
regarding
reporting/
timing
of
PMN
reporting
be
improved?

25.
Make
the
TSCA
Chemical
Substance
Inventory
be
made
available
on
the
website?
26.
Chapter
3
should
be
incorporated
into
another
chapter
since
it
is
only
1
page
in
August
1,
2003
Focus
Meeting
Comments
Page
4
length.

27.
Instructions
should
be
available
on
CDROM
with
hyperlinks
to
relevant
tables,
lists,
and
figures.

28.
Move
Appendix
B
definitions
to
main
text.

29.
In
Section
2.3.2,
include
an
example
of
a
single
product
manufactured
at
two
different
sites
that
exceed
300,000
pounds
at
both
sites.
How
do
you
insure
there
is
no
double
reporting
for
Part
III
information.

30.
Need
additional
examples
of
dual
use
chemicals.
For
example,
FDA
or
FIFRA
uses
plus
TSCA
uses.

31.
Can
an
online
dialog
be
established
for
IUR
reporting
issues,
similar
to
the
TRI
program?

32.
There
is
a
mistake
on
Form
U
in
manual
(
3,000,000
pounds
instead
of
300,000
pounds).

33.
Form
U
is
confusing.
Can
the
Sections
be
renumbered
A,
B,
and
C
to
distinguish
them
from
Parts
I,
II,
and
III?

Chapter
4:
Completing
Form
U
1.
Many
commenters
are
concerned
about
the
certification
statement.
a.
How
can
you
certify
accuracy
when
you
may
be
using
best
professional
judgement?
What
does
"
professional
judgement"
mean?
b.
The
certification
statement
should
be
changed
to
read
"
estimated
to
the
best
of
their
knowledge"
or
something
similar.
c.
What
enforcement
will
be
taken
for
errors
on
Form
U?
d.
Officials
are
wary
of
signing
a
truth
and
accuracy
statement.
e.
There
will
be
a
tendency
to
leave
things
blank
rather
than
certify
responses
that
may
be
guesses.
f.
Submitters
will
need
to
obtain
third
party
information
and
therefore
will
not
be
able
to
certify
this
information.
g.
Rule
combines
marketing
information,
environmental
uses,
health
and
safety,
etc.
No
one
person
can
complete
the
entire
form.
How
can
one
person
certify
that
all
information
is
correct?
h.
Can
separate
sections
have
separate
certification
statements?
i.
Suggest
adding
a
basis
of
estimate
code
(
as
done
for
TRI)
to
make
August
1,
2003
Focus
Meeting
Comments
Page
5
people
more
comfortable
about
signing
the
certification
statement.

2.
There
is
no
method
to
denote
where
estimates
were
provided
on
the
Form.
Companies
may
be
more
comfortable
certifying
the
truth
and
accuracy
of
the
Form
if
they
can
state
which
numbers
are
estimates.

3.
Expand
definition
of
`
readily
obtainable'
and
`
reasonably
ascertainable'
to
state
that
estimates
and
guesses
will
not
be
punishable
by
law.

4.
Submitters
may
not
want
to
release
email
addresses.

5.
Can
we
enter
`
NA'
anyplace
on
Form
U?
Please
make
this
clear.

6.
Comments
about
the
Dun
&
Bradstreet
number:
a.
What
if
you
don't
have
a
Dun
&
Bradstreet
number
for
your
plant
site?
b.
Provide
Dun
&
Bradstreet
contact
information.
c.
Can
you
leave
this
field
blank?
d.
Add
an
explanation
of
parent
company
and
site
Dun
&
Bradstreet
number.
e.
How
do
you
report
if
two
different
companies
share
the
same
site
and
same
Dun
&
Bradstreet
number?
Should
I
report
a
separate
form
for
each
company
and
report
the
same
D&
B
number?

7.
Will
EPA
be
available
to
assist
industry
with
providing
examples
to
use
in
the
Instruction
Manual?
Commenters
may
need
to
discuss
the
examples
with
EPA.

8.
The
Report
Number
box
on
Form
U
(
upper
right
hand
corner
of
page
1)
is
not
explained
anywhere
in
the
Manual.

9.
Improve
the
definitions.
Provide
regulation
citations.

10.
Align
the
definition
of
contiguous
plant
site
(
and
other
definitions)
with
TRI
or
clarify
how
definition
differs
from
TRI.

11.
Be
clear
on
both
Form
U
and
the
Instruction
Manual
to
report
`
B'
if
you
both
manufacture
and
import
a
chemical.

12.
Downstream
reporting.
a.
Information
in
Part
III
is
likely
to
be
a
guess.
Sites
will
not
have
any
idea
of
downstream
uses.
b.
How
far
downstream
do
you
need
to
report?
The
end
product
may
August
1,
2003
Focus
Meeting
Comments
Page
6
have
a
minute
amount
of
the
substance.
For
example,
nitrates
in
fertilizer
will
be
spread
onto
fields
and
be
absorbed
by
vegetables
that
go
into
the
consumer
market.
The
entire
United
States
population
may
be
exposed
to
fertilizers.
c.
How
do
we
report
on
Part
III
if
we
sell
our
chemical
to
a
distribution
center,
where
our
product
is
combined
with
quantities
of
the
identical
product
and
sold?

13.
What
documentation
is
needed
for
numbers
reported
on
Form
U?
Another
person
commented
that
EPA
should
not
be
overly
prescriptive
here.

14.
EPA
should
clarify
how
much
are
research
is
needed
to
complete
Form
U?
Also,
add
burden
estimate
to
help
submitters
decide
how
much
effort
to
put
into
gathering
the
information.

15.
Number
of
Workers
a.
Include
examples
in
Section
4.6.7
Number
of
Workers.
For
example,
are
administrative
staff
included?
Lab
people?
Maintenance
person?
b.
Provide
better
definition
of
reasonably
like
to
be
exposed.
Provide
examples
with
job
types.
c.
PPE
versus
engineering
controls
­
when
should
workers
be
included?
Case
Study
C
eliminates
workers
where
there
are
engineering
controls.
Guidance
on
engineering
controls
is
conflicting.
Engineering
controls
should
not
be
included
because
it
mitigates
exposure.
d.
Industry
often
uses
quantifiers
high,
medium,
and
low
for
worker
exposure.
Provide
methods
to
help
people
understand
what
information
EPA
is
looking
for
in
requesting
information
on
number
of
workers.
Is
EPA
looking
for
a
worst
case
estimate
or
a
realistic
estimate?
e.
The
current
method
allows
for
modest
amounts
and
frequency
of
exposure
to
be
overestimated.
f.
Industry
can
provide
number
of
workers
scenarios.
g.
Should
number
of
workers
be
provided
as
full­
time
equivalents
or
gross
number
of
workers?
h.
How
do
you
explain
to
workers
wearing
PPE
that
they
are
still
considered
exposed
by
EPA?
i.
Consider
reporting
the
concentration
of
the
chemical
when
a
worker
is
exposed.
Consider
a
de
minimis
limit
for
dilute
concentrations.
j.
Define
exposure
as
`
potential'
exposure.
August
1,
2003
Focus
Meeting
Comments
Page
7
k.
Do
not
use
the
word
`
exposure,'
but
use
the
term
`
collocation.'
l.
How
do
you
make
judgements
on
the
number
of
workers
exposed
at
downstream
sites?
m.
Should
contractors
be
included
on
number
of
workers
exposed?

16.
The
maximum
concentration
of
a
chemical
substance
in
products
produced
at
a
site
may
not
be
representative
of
the
majority
of
the
chemical
produced
at
the
site.
Modest
amounts
produced
at
a
higher
concentration
should
not
be
reported
because
it
will
lead
to
overestimation
of
exposures.
Some
commenters
suggested
using
a
mean
or
median
while
other
commenters
were
opposed
to
reporting
a
mean
or
median.
High
concentrations
may
only
occur
in
analytical
samples.
One
person
suggested
reporting
a
more
representative
concentration
where
the
amount
produced
at
high
concentrations
was
modest.

17.
Reporting
concentrations
in
wide
weight
ranges
will
result
in
overestimation
of
exposures.
Also,
what
range
do
you
use
if
your
product
is
shipped
as
3­
33%.

18.
Need
additional
clarification
on
physical
form.
For
example,
how
do
you
classify
a
slurry
or
a
solid/
liquid
suspension.
Dusty­
type
solids
have
a
different
level
of
exposure.
Can
you
add
particle
size
parameters?
How
do
you
report
if
the
physical
form
depends
on
handling?

19.
Section
4.5.3
­
what
is
meant
by
trade
name
reactant?
Do
you
want
to
replace
`
reactant'
with
the
`
ingredient'?

20.
Rounding
a.
How
do
you
round
production
to
the
nearest
10%
without
reporting
greater
than
100%.
(
I.
e.,
26,26,48
rounded
=
110)
b.
Rounding
to
the
nearest
10%
should
be
up
to
the
submitters.
c.
Define
the
rounding
rules.

21.
Write
`
Leave
Blank'
on
Form
for
Production
Volume
Range.
It
is
not
clear
that
this
does
not
need
to
be
reported.

22.
A
commenter
did
not
want
EPA
to
be
overly
descriptive,
especially
if
it
requires
extra
recordkeeping
and
level
of
effort.

23.
The
document
states
that
readily
obtainable
information
may
include
estimates,
are
estimates
required?
Are
submitters
required
to
make
best
professional
judgement
estimates?
If
submitters
are
required
to
provide
estimates
can
they
report
a
code
for
the
basis
of
these
estimates.
August
1,
2003
Focus
Meeting
Comments
Page
8
24.
Can
we
check
the
NA
box
for
Part
III,
Section
II
if
we
sell
our
chemical
directly
for
commercial/
consumer
use?

25.
The
children's
use
response
permits
submitters
to
enter
a
`?'
for
unknown.
There
is
no
place
to
enter
unknown
for
other
responses.

26.
EPA
should
provide
a
flow
diagram
for
providing
use
information.
It
would
be
helpful
to
have
a
decision
tree
for
this
section.

27.
Which
processing
and
use
code
should
you
use
for
substances
added
to
a
reactor
but
don't
react,
i.
e.
solvent,
and
are
later
removed?

28.
There
is
an
error
in
Table
4­
7,
in
the
last
example
100%
should
be
reported
rather
than
97%.

29.
EPA
should
provide
instruction
on
how
to
perform
file
searches.
Submitters
will
need
to
contact
many
people.

30.
The
combinations
of
process
or
use,
NAICS,
and
IFC
becomes
very
complicated.
For
example,
ethylene
glycol
has
42
combinations
and
manufacturers
do
not
have
enough
information
to
determine
which
are
the
top
ten
that
should
be
reported.

31.
The
Instruction
Manual
is
not
useful
for
Part
III
reporting.
Submitters
may
not
have
all
the
information
required
and
therefore
it
is
hard
to
determine
the
top
ten
combinations.

32.
If
I
know
some
general
uses
for
a
chemical
I
manufacture,
but
have
no
specific
information,
how
should
I
complete
Part
III?
This
applies
specifically
to
chemicals
I
sell
to
a
distribution
center.

33.
In
Case
Study
G,
the
submitter
could
not
obtain
all
the
information
so
it
was
left
blank.
Is
this
how
submitters
report?
How
will
EPA
know
that
this
information
is
not
readily
obtainable
and
therefore
not
pursue
enforcement
actions
for
not
fully
completing
the
form.

34.
Provide
additional
guidance
on
reporting
of
intermediates.
There
could
be
unreacted
intermediates.

35.
Give
details
on
the
definition
of
readily
obtainable
and
link
to
CFR.
(
Folks
were
unable
to
find
the
definition
in
the
CFR)

36.
Insert
the
word
`
industrial'
into
the
title
of
the
table
for
reporting
number
of
August
1,
2003
Focus
Meeting
Comments
Page
9
workers,
i.
e.
number
of
industrial
workers
exposed.

37.
Add
examples
into
section
where
the
topic
is
discussed.
It
will
be
hard
for
users
to
flip
back
and
forth
to
definitions
and
case
studies.

38.
Do
you
stop
reporting
downstream
uses
if
the
chemical
is
incorporated
into
an
article?
How
far
do
you
follow
­
is
there
a
deminimis
level?

39.
Provide
additional
guidance
on
inorganics.
Companies
may
revisit
how
they
classify
inorganics.

40.
In
Table
4­
5,
code
PF,
processing
into
a
reaction
product,
should
be
PC.
Clarify
these
definitions.

41.
In
Table
4­
10:
a.
Provide
definitions
for
commercial
and
consumer
product
categories.
b.
Clarify
potential
overlaps
such
as
C14,
polishes
and
sanitation
goods,
and
C16,
soaps
and
detergents.
c.
Include
the
word
`
nonpesticidal'
in
parentheses
after
C14,
polishes
and
sanitation
goods.
d.
Are
polishes
and
sanitation
goods
that
are
controlled
under
FIFRA
excluded
from
IUR
reporting?

42.
Are
federally
permitted
releases
included
in
IUR
reporting?

43.
A
CFR
notice
(
not
sure
which
one)
referenced
in
the
Instructions
Manual
does
not
exist.
See
#
35
Case
Studies
1.
For
the
case
using
copper
sulfate,
the
pesticidal
use
is
exempt.
For
the
case
study
using
xylene,
the
use
is
exempt
but
the
pesticidal
use
is
included
in
the
production
volume.
Do
you
include
non­
TSCA
uses
in
the
production
volume?
Is
there
a
distinction
between
active
and
inactive
ingredients
in
pesticides.
Please
be
very
clear
in
the
document.

2.
Several
fertilizers
(
such
as
urea)
are
used
as
solvents
in
pesticide
manufacturing.
Are
these
chemicals
exempt?

3.
Can
EPA
provide
any
additional
guidance
on
NAICS
codes?
There
is
an
overwhelming
number
of
codes.
August
1,
2003
Focus
Meeting
Comments
Page
10
4.
How
should
submitters
report
number
of
workers
for
Part
III?
Are
reference
material
or
rules
of
thumb
available?

5.
More
explanatory
text
is
required
in
the
case
studies.
For
example,
in
Case
Study
B
how
is
the
cosmetic
use
reported?

6.
Can
EPA
provide
additional
guidance
for
determining
when
a
chemical
is
used
in
children's
products?
For
example,
why
do
chemicals
used
in
wood
products
(
Case
Study
G)
not
qualify
for
use
in
children's
products?

7.
How
do
you
report
if
you
import
a
chemical
as
an
article?

8.
Is
EPA
confident
in
the
list
of
partially
exempt
chemicals
reported
in
Appendix
C?

Chapter
5:
How
to
Assert
Confidentiality
Claims
1.
We
prefer
to
have
our
address
claimed
as
CBI
due
to
security
issues
(
theft
for
drug
use
and
terrorism).

2.
Are
there
only
2
questions
submitters
need
to
answer
when
claiming
manufacturing
site
identity
CBI?

3.
Clarify
when
written
justification
is
required.

4.
Will
applicants
be
notified
if
their
written
substantiations
for
CBI
claims
are
not
validated
by
EPA?

5.
How
does
a
company
proceed
if
they
want
to
remove
CBI
protection
or
resubstantiate
a
CBI
claim?

6.
How
do
submitters
determine
if
a
substance
is
on
the
confidential
Inventory?

7.
Please
provide
a
legal
definition
of
`
authorized
official.'

Amendments
and
Partial
Exemption
Procedures
1.
Will
there
be
guidance
on
draft
procedures
for
additional
partial
exemptions?

2.
Metals
should
not
be
classified
as
PBT
chemicals?

3.
Submitters
are
adverse
to
changing
reporting
period
to
earlier
in
the
calendar
year.
August
1,
2003
Focus
Meeting
Comments
Page
11
August
1,
2003
Focus
Meeting
Comments
Page
12
Persons
Attending
the
Public
Meeting
on
August
1,
2003
Paul
Ackerman,
Piper
Rudnick
LLP
Jane
Bradd­
Andersen,
E.
I.
du
Pont
de
Nemours
and
Company
Fred
Arnold,
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics
Glen
Barrett,
American
Petroleum
Institute
Karen
Beichert,
Dow
Corning
Wayne
R.
Bidstrup,
Cleary
Gottlieb
Kathy
Bishop,
Alcoa,
Inc.
Lisa
Burchi,
Bergeson
&
Campbell,
P.
C.
Jim
Cooper,
Synthetic
Organic
Chemicals
Manufacturing
Association
Jan
Connery,
ERG,
Inc.
Ruth
Curfman,
Dow
Corning
Matt
Dalton,
Inside
EPA
John
DiFazio,
Consumer
Specialty
Products
Association
Rod
Dwyer,
National
Mining
Association
Melody
Foley,
Cargill,
Inc.
Robert
W.
Freerksen,
E.
I.
du
Pont
de
Nemours
and
Company
David
Giamporcaro,
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics
Patrick
Gibson,
Lyondell
Chemical
Company
Joseph
Green,
Collie,
Shannon,
Scott,
PLLC
Mark
Herwig,
General
Electric
Corporation
Franklyn
Hall,
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics
William
C.
Herz,
The
Fertilizer
Institute
Chris,
Hibshman,
ERG,
Inc.
Tim
Jones,
Bayer
Corporation
Alison
Keane,
National
Paint
and
Coatings
Association
Elizabeth
King,
Chevron
Texaco
Energy
Research
and
Technology
Company
Don
Lederer,
Solutia,
Inc.
Doyoung
Lee,
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics
Wayne
Leipold,
Phelps
Dodge
Miami,
Inc.
Andrea
Malinowski,
E.
I.
du
Pont
de
Nemours
and
Company
Nhan
Nguyen,
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics
Amit
Pal,
E.
I.
du
Pont
de
Nemours
and
Company
Jesus
Peralta,
CF
Industries
Georgia
Pugh,
E.
I.
du
Pont
de
Nemours
and
Company
Larry
Rampy,
American
Chemistry
Council
Kathleen
Roberts,
American
Chemistry
Council
Mark
Scoville,
Scientific
and
Regulatory
Solutions,
L.
L.
C.
Susan
Sharkey,
U.
S
EPA,
Office
of
Pollution
Prevention
and
Toxics
Paul
Strege,
Johnson
Diversity
Gautam
Srinivasan,
U.
S.
EPA,
Office
of
General
Counsel
August
1,
2003
Focus
Meeting
Comments
Page
13
Lara
Swett,
NPRA
Michael
E.
Thelen,
Dow
Corning
Corporation
Mary
Ellen
Weber,
U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics
Lori
Weiss,
ERG,
Inc.
Sherry
Witte,
Procter
and
Gamble,
Inc.
Karel
Wright,
Atofina
Chemicals
