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

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

Meeting Summary

On August 3, 2022, representatives from EPA met with Boeing 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, Boeing gave an overview of their concerns regarding the upcoming compliance deadline for the for processing and distribution in commerce and the associated recordkeeping requirements for PIP (3:1) in certain articles, and in particular in articles that are used in new and replacement parts for aerospace vehicles. In discussing articles that contain PIP (3:1), Boeing emphasized the difficulty in identifying the exact parts that contain the chemical, and the difficulty in transitioning to an alternative for certain high safety rated uses. Boeing also provided further information on the testing, qualification, and manufacturing process and timelines for new and replacement parts for aerospace vehicles. Additionally, Boeing presented information on their use of PIP (3:1) in aviation hydraulic fluids, and in lubricants and greases, noting that these continue to be critical uses without easily available alternatives. EPA gave an overview of the TSCA section 6(h) rulemaking activities to date. Boeing indicated they would continue engaging with the EPA rulemaking process.

Attendees
EPA:
Niva Kramek
Cindy Wheeler
Gabriela Rossner

Boeing:
Peter Pagano
Carolyn Kupper 
Sturla Olsen
Dario Gomez 

