AMWA and the American Water Works Association (AWWA) submitted a letter to EPA’s TSCA Science Advisory Committee on Chemicals (SACC) on August 30 regarding the committee’s review of the agency’s draft risk evaluation for 1,4 dioxane. The SACC met July 29-August 2 to review and discuss draft risk evaluations for both 1,4 dioxane and cyclic aliphatic bromide cluster (HBCD). These are two of the first ten chemicals EPA published for the initial chemical risk evaluations, as required by TSCA § 6(b)(2)(A).
In the joint comments, AMWA and AWWA urged the SACC to reject the draft risk evaluation as it is currently written “because it is based on an inadequate problem formulation and is thus incomplete.” In particular, the associations expressed concern with EPA’s decision to exclude drinking water exposure from the assessment stating it “inappropriately constrains the analysis, such that it does not meet a reasonable and prudent definition of ‘fit for purpose’ given the clear intent for actions under the Toxic Substances Control Act (TSCA) to prevent avoidable health risks due to the use of chemicals in commerce.” The letter concluded with AMWA and AWWA recommending that EPA reform its TSCA problem formulation framework regardless of the committee’s recommendation for 1,4 dioxane.