Transcript for U.S. EPA's Public Webinar:

Fees for the Administration of the Toxic Substances Control Act under Section

26(b)

February 18, 2021

» "i"iiiir I 'Hii • if II:s from km II ¦"¦hi,, 11.''. I I'"

Thank you, everyone. Good afternoon, everyone. Thank you for joining EPA's Office of Pollution
Prevention and Toxics webinar on the Proposed Revisions to the Toxic Substances Control Act Fees Rule.
My name is Jeff Kohn. I work for the Stakeholder Engagement Branch in the Office of Pollution
Prevention and Toxics. We have 150 people on the line. During the webinar, we will be advancing the
presentation slides using WebEx. You can also download the slides from EPA's TSCA Fees Rule webpage.
Today's agenda shown on the screen right now is also on that webpage. Today's webinar will start with
a presentation from EPA, followed by a public comment period. EPA will not be answering questions
during the webinar. Those people who signed up to make remarks will have five minutes per person.
Emily, from Abt Associates, will introduce each commenter. If you have registered to make a comment,
please be sure you are connected properly through WebEx so Emily can unmute you. Again, if there's
any technical issues, you can use the chat function or email Sarah Swenson, swenson.sarah with an H at
the end of Sarah @epa.gov. With that, let's get started. Our first speaker this morning is Tanya Mottley,
Director of EPA's Existing Chemicals and Risk Management Division in the Office of Pollution Prevention
and Toxics. Tanya, please go ahead.

Ihiioductory Remarl n--irn 1 .«h .> III--olge IVIottlk , M/'.ir"

Thanks, Jeff. Hello, everyone. It's a pleasure to be here today. My name is Tanya Hodge Mottley and I'm
the Director of the Existing Chemicals Risk Management Division. I'm opening today's webinar on EPA's
proposed updates to the TSCA Fees Rule. And I'd like to emphasize how much we value your input. This
is a useful forum for the Agency to obtain public comment on the TSCA Fees Program.

But before I turn it over to my colleague, Brooke Porter, I want to leave you with a few thoughts. With
the amendments to the Toxic Substances Control Act that were enacted in 2016, we've been building a
new regulatory program from the ground up. We've taken some big steps to propose amendments to
the Fees Requirements established in 2018 and to ensure that the TSCA Fees Rule reflects real world
situations, ensures the equitable and fair distribution of these, and reduces the burden on small
businesses.

Last month, EPA published the proposed changes to the TSCA Fees Requirements established in 2018,
based upon over two years of the implementation experience and with the help of valuable stakeholder
input. Today, you will hear about how EPA is meeting the mandate to review and adjust as necessary the
fees every three years to ensure EPA is collecting sufficient funds to defray a portion of the costs of
carrying out important TSCA functions, including risk evaluations, test orders, and activities under the
New Chemicals program.

1

-------
We look forward to hearing from companies, trade associations, and consortia that represent affected
manufacturers and processors directly impacted by these rules, as well as individual organizations and
non-governmental groups interested in TSCA Fees. I want you to be aware of our work and through
meetings like today, contribute to the TSCA Fees Rulemaking. We'll be using today's webinar to bring
you up to speed on the key provisions of TSCA as it relates to TSCA Fees to inform you about the
proposed amendments to the TSCA Fees Rule and to outline the next steps in the process.

EPA is committed to an open and transparent dialogue with stakeholders and will be seeking input from
you on the best approaches for the TSCA Fees Program and the impact those approaches may have on
stakeholders. Your feedback is important as we develop a regulation that is practical and meets the
directives set out under TSCA and now is a critical juncture for you to be involved. We need and
appreciate your input, expertise and feedback to help finalize a successful TSCA Fees Rule that ensures
EPA can collect the appropriate funds to carry out its essential task of protecting humans and the
environment.

Thank you again for your interest in TSCA. On behalf of the Agency, I look forward to working with you
and we all look forward to working with you. And with that, I will now turn to our next speaker, Brooke
Porter. Brooke Porter is a Staff Lead on the TSCA Fees Rule rulemaking. And she will walk us through
today's presentation. Thank you, Brooke.

Presentation ok Porter, U.S. EPA

Thanks, Tanya. Thank you, everyone, for joining us today. I will start with statutory background. So TSCA,
as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016 provides the
EPA with authority to establish fees.

Fees are used to defray a portion of the costs associated with administering TSCA sections 4, 5, and 6, as
well as the costs of collecting, processing, reviewing, and providing access to and protecting from
disclosure as appropriate information on chemical substances under TSCA section 14. EPA is required by
section 26(b)(4)(F) to review and, if necessary, adjust the fees every three years, after consultation with
parties potentially subject to fees, to ensure that funds are sufficient to defray the costs of administering
TSCA.

On January 11, 2021, EPA published a proposal to amend the 2018 Fees Rule, including several
exemptions and changes to the fee requirements established in the 2018 Fees Rule. So the purpose of
the Fees Rule is to collect fees to defray 25% of the Agency's costs to administer: Section 4 which is
Testing and Development of Information on Chemicals; Section 5 - New Chemicals Program; Section 6 -
Existing Chemicals Program; and collecting, processing, reviewing, providing access to and protecting
information about chemical substances from disclosure as appropriate under TSCA section 14, as well as
providing EPA with a sustainable source of funding.

So, continuing on the overview on TSCA Fees which is fees for small businesses. TSCA section 26(b)(4)(a)
states that EPA must "prescribe lower fees for small business for small business concerns." Small
businesses are currently afforded an 80% discount for TSCA section 4, section 5 exemption submission,

2

-------
and EPA-initiated risk evaluations, as well as an 82.5% discount for TSCA section 5 premanufacture
notices, microbial commercial activity notices, and significant new use notices submission. Under the
2018 Fees Rule, EPA finalized an employee-based size definition modeled after the Small Business
Administration's standard. EPA is not proposing changes to that definition.

The proposed rule includes three new fee categories: TSCA section 4 Test Order Fee. EPA is proposing to
create a new fee for TSCA payable by recipients that elect to resubmit data per request of the Agency. If
EPA determines that the recipient did not comply with the terms or conditions of the order, such as
testing protocols, or if the company later determines that the data submitted under a testing order is
incomplete, inconsistent, or deficient.

The second category is a Notice of Commencement of Manufacture or Import Fee. NOC submissions
ensure that a chemical substance is manufactured after TSCA section 5(a)(3) review appears on the TSCA
inventory. EPA is proposing to collect section 5 fees for NOC submissions.

The third category is a Bona Fide Intent to Manufacture or Import Notice Fee. EPA is proposing to collect
TSCA section 5 fees for bona fide notices. A company that intends to manufacture a chemical not listed
in the public TSCA inventory may submit a Bona Fide Intent to Manufacture or Import Notice to obtain
written notification from EPA, whether the chemical substance is included on a confidential inventory.

The proposed rule also includes a proposed exemption. Proposed exemptions for entities subject to
EPA-initiated risk evaluation fees, including importers of articles containing a chemical substance subject
to an EPA-initiated risk evaluation; producers of a substance subject to EPA-initiated risk evaluation that
is produced exclusively as a by-product; producers or importers of a substance subject to an EPA-
initiated risk evaluation that is produced or imported exclusively as an impurity; manufacturers,
including importers, of small quantities solely for research and development activities; entities
manufacturing, including import, less than 2,500 pounds of a chemical substance subject to an EPA-
initiated risk evaluation fee, and manufacturers, including importers, of chemical substances produced
as non-isolated intermediate.

Other proposed updates update cost estimates for administering TSCA sections 4, 5, and 6 and
individual fee calculation methodology, including associated administrative costs for confidential
business information activities under TSCA section 14; propose a production volume-based fee
allocation for EPA-initiated risk evaluation fees; propose that export-only manufacturers pay fees for
EPA-initiated risk evaluations; and propose various changes to the timing of certain activities required
throughout the fee payment. Moving on to the timing for fee activities in the proposals and the
proposed rule. So, the 2021 proposal includes extending the initial payment for a manufacturer-
requested risk evaluation to 180 days over three payment installments and in the 2018 final rule, this
was 30 days over two payment installments.

In the 2021 proposal for the EPA-initiated risk evaluation, payment is collected over two installments
and the first payment of 50% is to be collected in 180 days. And the second payment is due no later than
545 days after the EPA publishes the final scope of the chemical evaluation. In the 2018 final rule
payment, it is collected in one installment over 120 days. And in the 2021 proposal, 90 days have been

3

-------
proposed to notify EPA of intent to form a consortium from the featuring event. In the 2018 final rule, it
is 60 days. And to wrap up, I encourage you to visit the TSCA Fees webpage for more information on the
2021 proposed rule. And with that, I will turn it back to Jeff. Thank you, everyone.

IP11!'Ill' ^innii11¦ ~ni IVii'vj
James Cooper

Thank you and good afternoon, everybody. And thank you EPA for, again, hosting another TSCA webinar.
I think these are very important for the transparency of the program and also to create that spirit of
cooperation among the various stakeholders, so I appreciate the opportunity. First and foremost,
generally, TSCA Fees should be based on actual services provided and follow the OMB Circular Number
825, especially the revised version. TSCA Fees should be based on market prices. That's under section 6
(a)(2)(b) of the circular. And EPA probably needs to conduct a benchmarking study that includes non-
governmental service providers to really gauge what the actual market prices are. And I've not seen
such a study conducted thus far. And also, fees really should vary according to the number of conditions
that we use that are to be considered where an intermediate that has made one or two uses. That's far
different from, let's say, something that's used commercially or a consumer product that may have any
different number of users. And so the actual amount of work that goes into that service is going to be
quite different.

More specifically, EPA does ask some questions, but AFPM believes that EPA should use ranges based on
average production and import volumes. That way, CBI won't be disclosed. And still, it's probably the
most equitable way to split the cost if the companies can't figure out how they're going to divide the
costs on their own. AFPM does not believe the fees should be collected for section 4 actions, primarily
because the reviews of the data that are submitted under section 4 actions are going to be conducted
under section 5 and section 6 and fees are already charged for those reviews. And so, it's actually
resulting in a double charging when you're charging them to submit data and then you're also charging
them to review under different sections. Do one or the other, but not both.

Let's see. Just bear with me for a moment. I didn't expect to be coming up that quickly since my name
begins with a J. The Bona Fide Intent, we do support the Agency's proposal to collect a fee for that.

There is a service that is provided. Regarding the Notice of Commencement, I don't know if the same
fees should be collected. Maybe it should be at least a reduced fee because the Notice of
Commencement doesn't require the same level of service that a Bona Fide Intent entails. Basically, with
the Notice of Commencement, EPA is primarily going to chemical abstracts service and then placing it on
the Inventory. Let me see what else I've got here.

Regarding exports, TSCA is quite clear and has been since its inception that TSCA authorizes the Agency
to regulate chemicals in commerce and that means US commerce. If a substance is manufactured solely
for export, even if it's sold into commerce by other market players, that's really not subject to a lot of
other provisions at TSCA and it shouldn't be subject to TSCA Fees as well because it's not sold into
commerce, thereby not presenting any kind of risk in the United States. So that's kind of outside EPA's
jurisdiction.

4

-------
When it comes EPA's justification on the containers, I think maybe there was a misinterpretation of the
phrase "bears the stamp of labeling stating that such substance makes your article or articles intended
for export." Basically, all containers, they go for export. If they are going for export, they have to bear -
certainly, there are clear regulations on that. And other containers aren't subject to the same thing. And
so, it basically would be far simpler just to exclude export-only substances, if that's the case. In
conclusion, AFPM has always supported - even when doing the TSCA revisions on the Hill, we advocated
that the EPA should be authorized to collect fees for the services. But one thing that concerns us is how
EPA is estimating those fees and whether or not there's been actual benchmarking done and AFPM
would appreciate if EPA, in the future, conduct a benchmarking study and base these fees on the
realistic market conditions. And also, maybe even providing options where if a full-risk evaluation is to
be conducted, perhaps the regulated community can use the same type of service providers that EPA
uses as contractors to conduct those risk evaluations and submit a more complete dossier that includes
the risk evaluation to EPA. EPA's only task would be to review that information and render its opinion
with that information. And again, thank you for the opportunity.

Julia Rege

This is Julia Rege with the Alliance for Automotive Innovation. Auto Innovators is a trade association that
represents automakers that sell about 90% of the new vehicles in the US, as well as suppliers and
technology and mobility companies. Innovators fully supports EPA's goals of ensuring a sustainable
resource base to continue the effective implementation of TSCA as in the Lautenburg Chemical Safety
Act of 2016. Assessing fees on the primary manufacturers of chemicals places the responsibility on the
first step in the supply chain and provides EPA with a predictable and sustainable set of responsible
parties. In exempting processors in the original rule, EPA recognizes the pitfalls of charging duplicative
fees up and down the supply chain, as well as the complexities associated with data collection from the
numerous and multi-tiered systems of downstream users. Since EPA began its Implementation of the
Lautenburg Act, our association and our members have had the opportunity to learn from EPA about the
types of data and information that they need from our sector to conduct accurate risk evaluations.

EPA staff have, likewise, the opportunity to learn about the supply chains associated with the import of
articles that may contain any of the high priority chemicals. This work is critical to the EPA's goals of
protecting workers, the public, and the environment. I have four items to briefly address today
regarding the proposal. First, we'd like to express appreciation for EPA's proposed tiered fee structure.
This recognizes that not all uses are the same or even in the same amounts. It also continues to meet
EPA's funding needs without overburdening smaller manufacturers or users covered by the rule.

Second, in addition to the challenges and undue burden presented by data collection impacting
thousands of imported articles, inclusion of downstream users, officers, importers of articles, R&D users,
etc. will double count fees in the supply chain and detract from the overarching need to conduct risk
assessments. It is important to recognize that the exemptions EPA has proposed in this Fees Rule in no
way constrain EPA from assessing these activities in its risk evaluation. These assessments - not the
fees - are the primary tool for assessing health and environmental impacts, leading to actions to
manage risks throughout the supply chain from manufacturer to processor to user to consumer to

5

-------
environment. And third, as we will detail in our comments, some additional clarification and process
improvements are likely due to the certification, identification, and exemption provisions to clearly
outline responsibilities by user type.

And then finally, we do have one question for EPA today, and that is about how today's webinar and
public comments will be considered in the context of the upcoming comment deadline? We are
wondering if there's any plans to extend that comment deadline based on today's event. Thank you so
much for your time today.

Kat Gale

Good afternoon. My name is Kat Gale and I'm a manager of the Regulatory and Technical Affairs
Department for the American Chemistry Council. ACC appreciates the opportunity to provide feedback
on the approach to the administration of the Toxic Substances Control Act Rule. I would like to note that
ACC has submitted a request for extension of the public comment period by 30 days from its current
deadline to March 27, 2021. In this comment, I'd like to highlight several points which will be discussed
further in our written comments on the proposal.

First, the proposal would increase the TSCA section 6 fixed program fees, which includes increasing the
fees we've collected for the EPA-initiated risk evaluation by approximately 87.6% without providing a
thorough economic analysis to substantiate that increase. ACC appreciates the Agency's need to recoup
the costs associated with creating a positive program based on experience, recent risk evaluation, and
prior risk management. However, the Agency is proposing to do so without having provided a detailed
economic analysis sufficient to substantiate that the proposed increase is warranted. The proposed
increase is substantial and would have a significant impact on the stakeholders. The current fees cycle
revealed that in some instances, a single manufacturer responsible for only a small quantity of
production could be responsible for the full fee associated with the risk evaluation. This is not an
equitable outcome.

Second, the proposed methodology for calculating fees for the EPA-initiated risk evaluation, with the
potential confidential business information concern, places an excessive reporting burden on the
stakeholders and additional burdens on EPA. The methodology proposed uses an average actual
production value which would present CBI concerns for stakeholders that claim the sensitive
information is confidential. Stakeholders are business competitors and those that choose to maintain
their production volume as confidential could be forced into involuntary disclosure of CBI as the fee
calculations are based on volume and in the manner proposed.

Further, the collection of production volume data is a detailed and time-consuming process. If a
chemical is identified during an off chemical data reporting year, obtaining and reporting the data
presents an excessive burden on stakeholders. Finally, the calculation of numerous fees based on
numerous factors also presents a significant burden on EPA. ACC is developing and plans to present
alternative methodologies in our written comments. These alternatives might include using tonnage
bands instead of actual volumes and/or set fees for section 6 evaluation based solely on the company's
tonnage, i.e., regardless of how many participants are active manufacturers or importers. Third,

6

-------
manufacturers and importers that have not paid the TSCA Fee for a substance should be restricted from
entering the market for a period of five years or the manufacturers and importers that have otherwise
left the market should have a path back into the market. These "new markets entrants" and "market re-
entrants" should be required to pay a portion of the TSCA Fee prior to entering. The current "free
market/free rider" system where manufacturers can enter the market as soon as the TSCA Fee [poor
audio quality] is unfair to those manufacturers [poor audio quality]. Further, barring manufacturers from
participating in the market for a period of five years especially in light of the proposed research and
development exemption utilizes EPA support in a manner that might impede unduly or create
unnecessary economic barriers to technical or logical innovation contrary to Congressional intent.

ACC will provide further details on this recommendation in written comments. Finally, the exemptions
proposed should apply to both the manufacturer or the importer of the high-priority substance. ACC
appreciates EPA's addition of the five exemptions and a proposed rule. The proposed exemptions
specifically differentiate between production of the substance and the import of a substance, as well as
the manufacturers of the substance and importers of a substance. ACC recommends that the
exemptions be revised to include both manufacturers and importers of the substance and substances
that are both produced and imported. We want to thank you for your time and continued engagement
with stakeholders on this important issue.

Rich j ifison

Good afternoon. I'm Dr. Richard Denison. I'm a Lead Senior Scientist with Environmental Defense Fund.
Among the key reforms made to TSCA in 2016 was the expansion of EPA's authority to collect fees from
the industry. You have the freight costs in implementing the law. There was widespread agreement,
including by industry, that EPA needed more resources to faithfully execute TSCA and that industries
should significantly contribute financially.

Unfortunately, that purpose has disappeared almost entirely from the current proposal, which is
metamorphosed into a new purpose entirely divorced from TSCA to reduce asserted burdens on
industry, without regard to the impacts that will have on EPA's implementation of the law or helping
environmental protection from chemical exposures. The EPA repeatedly invokes industry burden
reduction as justification for proposed changes to the rule citing no evidence other than industry
complaints that the fees actually impose on due burdens.

The EPA's proposed changes also fail even to acknowledge, let alone assess, the effects of the reduced
or the delayed fees that would result from its proposed changes on EPA's ability to carry out its duties
under TSCA. Let me address specifically the exemptions from fee paying. EPA has proposed no fewer
than six exemptions from the payment of fees for companies whose chemicals are undergoing risk
evaluations. There are many problems with this approach. These activities constitute forms of
manufacturing under TSCA. They are activities that TSCA requires EPA to include in the scope of a risk
evaluation and hence, EPA will incur costs in evaluating those activities. Neither TSCA nor

EPA's final 2018 Fees Rule provides any basis for these exemptions. Indeed, in their comments on the
2018 proposed Fees Rule, numerous industry stakeholders requested EPA to include some of these and

7

-------
many other exemptions from the fees. In the final rule, EPA firmly rejected those requests, issuing a final
rule without any of the exemptions and noting that TSCA requires EPA to evaluate chemicals under
these conditions of use.

In theory, exempting some manufacturers of a chemical would simply mean that the remaining
manufacturers would have to pay more. There is real concern that exemptions could result in no
companies being left to pay fees and will otherwise create inequities. This is not theoretical. After EPA
applied these exemptions to its list of manufacturers of the 20 chemicals now undergoing risk
evaluations, which they did with no transparency, the number of subject chemicals dropped
dramatically and in one case, left no - zero companies - that meant that EPA and hence, the taxpayer
would have to pay the full $5.7 million for that assessment.

EPA never addresses what will happen if the basis for a company's claimed exemption changes or if its
certification is found not or no longer to be true. These clearly should be considered violations of TSCA.
EPA has also not addressed what the situation would mean for the fees other companies have paid for
that chemical. The policy basis for these exemptions is highly questionable. On what reasonable basis,
for example, would a company not know that a product or a chemical it makes or imports is
contaminated with an impurity or a by-product. Knowledge about the composition of one's products
was long ago identified as a pillar of extended product producer responsibility policies that the industry
purports to have embraced years ago.

EPA has further proposed spreading out and delaying the payment of fees for risk evaluations, yet it fails
to acknowledge, let alone assess, this proposal's impact on EPA's ability to conduct risk evaluations.
EPA's ability to hire staff and engage contractors to do the necessary work requires stability in its budget
and advanced planning, both of which will be adversely affected if you do not receive fees on time and
early. Some of the same companies that pressed EPA for this accommodation are adding to EPA's
burden by requesting that it conduct risk evaluations of their chosen chemicals. If cash were really so
tight, they could save some by pulling back those requests and avoid paying the fees to cover their share
of those risk evaluations. Finally, if fees are lost or delayed due to EPA's accommodation of industry
concerns, that reduces EPA's capacity to conduct timely, robust risk evaluations. The TSCA clock is
already ticking on the next 20 evaluations and EPA is already well behind schedule. In sum, EPA should
not introduce exemptions from fee paying in updating the Fees Rule. Thank you for your time.

Lindsay McCormick

Hi, my name is Lindsay McCormick and I'm a program manager with Environmental Defense Fund. I'd
like to start by saying there are several aspects of the proposed Fees Rule that we support, including the
introduction of three new fee categories and the addition of fee requirements for manufacturers that
exclusively export chemicals subject to EPA-initiated evaluations. However, we are concerned that EPA
is continuing to underestimate the agencies baseline cost to administer TSCA, which will ultimately
result in recouping fewer fees than warranted.

In the proposal, EPA both underestimated the Agency's costs for many of the activities it did include and
omitted altogether the cost of other activities it must undertake, in which the fees to be collected are to

8

-------
help defray. I will briefly describe some examples of these underestimates and omissions under five
sections of the law.

First, with respect to section 4 - Testing, EPA continues to grossly underestimate the amount of testing
it needs to conduct to robust risk evaluations and instead over-rely on voluntary information
submissions, as exemplified by its recent proposed section 4, Involuntary Information Collection Request.
Second, with respect to section 5 - New Chemicals, while the Agency has proposed some new fees, it
fails to adequately address costs of developing consent orders and significant new use rules, omitting
mention of them in its proposal on the supporting economic analysis.

Third, with respect to section 6 - Existing Chemicals, EPA states it estimated the costs of conducting risk
evaluations based on the hours staff reported working on the first 10 risk evaluations. Given that those
risk evaluations included or excluded or omitted major known sources of exposure, there is little doubt
that EPA's estimates significantly understate the cost of conducting the comprehensive evaluations
TSCA and sound science require.

Proposed prioritization and risk management actions under section 6. It is far from clear whether or how
EPA included the cost of these activities in its estimates of cost. EPA has provided no line item costs, let
alone a break down for the component steps each activity entails. EPA says it estimates costs per risk
management based on prior actions, but with one partial exception. These actions were never finalized
and were recently abandoned altogether. Moreover, they were far narrower in scale than the risk
management rules EPA is now undertaking. Finally, EPA's estimated cost for administering section 6 has
actually gone down by nearly $2 million through the 2018 Rule, which seems highly questionable given
EPA's greatly increased risk evaluation and risk management workload.

Fourth, with respect to the cost of collecting, processing and reviewing the information based on a
continued misreading of the law, EPA has failed to include any estimates beyond the cost of reviewing
confidential business information or CBI claims under section 14. For example, EPA did not include any
costs for developing reporting rules under section 8, which may be critical in providing information
needed to inform section 6 prioritization, risk evaluation, and risk management activities. Indeed, EPA is
reportedly developing the first such rule now since TSCA was amended. And finally, for section 14 -
Confidential Information, EPA's estimated costs are unreasonably low, as much as fivefold lower than
EPA's prior 2016 budget estimate for the much narrower set of activities carried out under the old law.

EPA has failed to provide a breakdown of costs for many new duties under this heavily amended section
of TSCA. EPA provided no estimate of how many CBI claims it received or must review and omitted any
estimate of its cost to provide access to CBI to qualified persons or to provide public access to
information that does not qualify for protection from disclosure. EPA also grossly understated its cost
for faithful and timely review of confidentiality claims under TSCA. EPA has failed to carry out its new
obligations under amended TSCA in this area, which it repeatedly blames on insufficient resources. Just
one example, EPA has failed to review on time a third of the Notices of Commencement of
Manufacturing it had received in the past four years that claim the identity of the chemicals to be
confidential, or to assign a unique identifier the law requires in cases where it approves such claims.

9

-------
In summary, as a result of these underestimates and omissions, EPA is proposing fees below the levels
required by TSCA and insufficient to recoup the allowable cost. We urge EPA to remedy these
deficiencies in its final Fees Rule. Thank you for the opportunity to comment.

Closing [Vim irks from I iiki I liin '' II II

Thank you for all the wonderful comments and for the participation in today's webinar on the Proposed
Revisions to the TSCA Fees Rule. An audio recording and a transcript of this webinar will be available on
the TSCA Fees website. The team here in the Office of Pollution Prevention and Toxics looks forward to
continued dialogue on this issue and other issues such as risk management under TSCA. Thank you again
for joining us.

10

-------