     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 July 12 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) under two uses excluded from the prohibition in the rule; as an intermediate in a closed system to produce cyanoacrylate adhesives, and in new and replacement parts for motor and aerospace vehicles. Henkel presented that most of their use of PIP (3:1) is as an intermediate in a closed system to produce cyanoacrylate adhesives, and gave an overview of their facility processes, engineering controls, and worker protection measures. Additionally, Henkel presented on their use of PIP (3:1) in motor and aerospace vehicles, which they stated is a smaller fraction of their business compared to adhesives. Henkel discussed how PIP (3:1) is used in wire insulation and devices used for military and medical applications. 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:
Cindy Wheeler
Gabriela Rossner

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