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

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

Meeting Summary

On July 12, 2022, representatives from EPA met with the Association of Equipment Manufacturers (AEM) to discuss the reconsideration of exclusions as indicated 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, AEM gave an overview of their memberships' 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. As outlined in their comments, AEM presented on the difficulties of identifying and replacing PIP (3:1) in articles present in the several layers deep supply chains for large manufacturing equipment and estimated that 7 years would be an optimistic timeline for phasing out of the chemical. AEM reiterated their request for EPA to include industrial equipment (such as mobile industry equipment) in the definition of motor vehicle and emphasized that, as supported by public comments, there is an overlap in supply chains and parts manufacturing between the two industries. EPA gave an overview of the TSCA section 6(h) rulemaking activities to date. AEM indicated they would continue engaging with the EPA rulemaking process.

Attendees
EPA:
Niva Kramek
Cindy Wheeler
Gabriela Rossner

AEM:
Jason Malcore
