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

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

Meeting Summary

On August 9, 2022, representatives from EPA met with the Aerospace Industries Association (AIA) 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, AIA gave an overview of their membership's 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. Additionally, AIA presented information on the 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. AIA indicated they would continue engaging with the EPA rulemaking process.

Attendees
EPA:
Niva Kramek
Cindy Wheeler
Gabriela Rossner

AIA:
Mark Sudol
Mark Herwig
Costa Triantafyll
Caroline Kupper 
Tim Sheehan
Lindsey Bean
Sophia Danenberg
Sally Gestautas


