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October 3, 2019

EPA Publishes TSCA SACC Meeting Minutes and Final Report on Draft Risk Evaluation for PV29

Lynn L. Bergeson Carla N. Hutton

On September 30, 2019, the U.S. Environmental Protection Agency (EPA) announced the availability of the meeting minutes and final report for the June 18-21, 2019, meeting of the Toxic Substances Control Act (TSCA) Science Advisory Committee on Chemicals (SACC) on the draft risk evaluation for Pigment Violet 29 (PV29).  SACC’s report addresses the scientific issues being considered by EPA regarding the peer review for the draft risk evaluation.  As reported in our November 16, 2018, memorandum, “EPA Publishes First Draft TSCA Chemical Risk Evaluation,” the draft risk evaluation states that EPA considered all reasonably available data for PV29 to make a determination of whether the risk it poses is unreasonable.  EPA “concludes that C.I. Pigment Violet 29 does not present an unreasonable risk of injury to human health or the environment, without considering costs or other non-risk factors, including no unreasonable risk to potentially exposed and susceptible subpopulations identified as relevant, under the conditions of use.”  EPA requested SACC to provide advice and recommendations on questions concerning:

  • The overall content, organization, and presentation of the draft risk evaluation;
  • Systematic review;
  • Physical chemical properties/environmental fate;
  • Exposure and releases;
  • Environmental effects;
  • Human health;
  • Risk characterization/risk determination; and
  • Supplemental analysis.

The report notes that this first SACC peer review is the first time the TSCA program is making non-TSCA confidential business information (CBI) available to peer reviewers.  According to the report, EPA requested comment on the process, integration, and clarity related to the use of the CBI that was provided.  EPA provided SACC members TSCA CBI training, and they were permitted to review the full studies as part of their peer review.  The report states that upon a comparison of the full (unredacted) studies with the redacted studies, SACC reached consensus that the nature of the redactions do not materially impact the draft risk characterization.  SACC agreed that the summary statistics provided in the unredacted version of the reproduction/development study were consistent with the animal data in the redacted version of the study.  SACC made recommendations to EPA about how to process CBI information for use by SACC and the public for future assessments.