     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
                                       
                             OFFICE OF CHEMICAL SAFETY
AND POLLUTION PREVENTION
MEMORANDUM FOR THE RECORD

RE:  	Meeting with Henkel on the Regulation of Persistent, Bioaccumulative, and Toxic Chemicals Under TSCA Section 6(h)
List of Contents
 Meeting Summary
 Attendees
Meeting Summary

On November 14, 2022, representatives from EPA met with Henkel to discuss comments submitted in docket EPA-HQ-OPPT-2021-0598 on the Regulation of Persistent, Bioaccumulative, and Toxic Chemicals Under TSCA Section 6(h); Phenol, Isopropylated Phosphate (3:1); Compliance Date Extension, published March 8, 2022. During the meeting, Henkel discussed their use of PIP (3:1) as an intermediate in a closed system to produce cyanoacrylate adhesives, Henkel presented an overview of their facility processes, engineering controls, chemical processes, and worker protection measures. EPA gave an overview of the TSCA section 6(h) rulemaking activities to date. Henkel indicated they would continue engaging with the EPA rulemaking process, specifically on details of worker protections for PIP (3:1) use in a closed system to produce cyanoacrylate adhesives.
Attendees:
EPA:
Damaris Christensen
Sofia Sonner
Scott Drewes
Victoria Ellenbogen

Henkel:
Martina Werner
Senthil Pichandi
Gary Pierson
Rebecca Coons
Kevin McKenney
