TSCA Section ,	terniinatioii for Microbial Commercial Activity Notice (MCAN) J-

18-0012

Number: J-18-0012

TSCA Section 5(a)(3) Determination: Microorganism not likely to present an unreasonable
risk (5(a)(3)(C))

Chemical Name:

Generic: Genetically modified yeast

Conditions of Use (intended, known, or reasonably foreseen)1:

Intended use(s) (generic): Production of an agricultural product.

Known and reasonably foreseen use(s): None.

Summary: The microorganism is not likely to present an unreasonable risk based on low human
health hazard and low environmental hazard associated with the recipient microorganism and
introduced genetic material. The recipient microorganism is not pathogenic to humans or animals
and has a long history of safe use in food and industrial applications. The introduced genetic
modifications pose low concern for human health and environmental hazard.

Human Health Hazard2: Human health hazard is relevant to whether a new microorganism is
likely to present an unreasonable risk because the significance of the risk is dependent upon both
the hazard (pathogenicity/toxicity) of the microorganism and the extent of exposure to the
microorganism. EPA estimated the human health hazard of this microorganism based on data
for the recipient parental strain as well as the genetic modifications. There is low concern
for human health hazard for the microorganisms based on the recipient strain not being a
human pathogen and the introduced genetic material only including well-characterized
sequences that are not expected to confer pathogenic traits nor cause toxicity or allergic

1	Under TSCA § 3(4), the term "conditions of use" means "the circumstances, as determined by the Administrator,
under which a chemical substance (including an intergeneric microorganism) is intended, known, or reasonably
foreseen to be manufactured, processed, distributed in commerce, used, or disposed of." In general, EPA considers
the intended conditions of use of a new chemical substance to be those identified in the section 5(a) notification.
Known conditions of use include activities within the United States that result from manufacture that is exempt from
MCAN submission requirements. Reasonably foreseen conditions of use are future circumstances, distinct from
known or intended conditions of use, under which the Administrator expects the MCAN microorganism to be
manufactured, processed, distributed, used, or disposed of. The identification of "reasonably foreseen" conditions of
use will necessarily be a case-by-case determination and will be highly fact-specific. Reasonably foreseen
conditions of use will not be based on hypothetical or conjecture. Accordingly, EPA will apply its professional
judgment, experience, and discretion when considering such factors as evidence of current use of the new
microorganism outside the United States, evidence that the MCAN microorganism is sufficiently likely to be used
for the same purposes as existing microorganisms that are similar, and conditions of use identified in an initial
MCAN submission that the submitter omits in a revised MCAN. The sources EPA uses to identify reasonably
foreseen conditions of use include searches of internal confidential EPA MCAN databases (containing use
information on analogous microorganisms), other U.S. government public sources, and Internet searches.

2	A microorganism is considered to have low human health hazard if it is not known to be a frank human pathogen
that causes disease in healthy adults, and/or animal studies have demonstrated a lack of pathogenicity or toxicity; a
microorganism is considered to have high human health hazard if there is evidence of adverse effects in humans or
conclusive evidence of severe effects in animal studies. In the absence of animal data on a microorganism, EPA may
use other data or information obtained through literature searches.


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response in mammals.

Environmental Hazard3: Environmental hazard is relevant to whether a new microorganism is
likely to present unreasonable risks because the significance of the risk is dependent upon both
the hazard (pathogenicity/toxicity) of the microorganism and the extent of exposure to the
microorganism. EPA estimated the environmental hazard of this microorganism based on data
for the recipient parental strain as well as information on the genetic modifications. There is
low concern for environmental hazard for the microorganism based on the recipient not
being an animal or plant pathogen, and the introduced genetic material consists of genes that
are not expected to be hazardous if the new microorganism were to be inadvertently released
to the environment.

Exposure and Risk Characterization: The exposure to a new microorganism is potentially
relevant to whether a new microorganism is likely to present unreasonable risks because the
significance of the risk is dependent upon both the hazard (e.g., pathogenicity/toxicity) of the
microorganism and the nature and extent of exposure to the substance. Due to low hazard, EPA
believes that this microorganism would be unlikely to present an unreasonable risk even if
exposures were high. Therefore, EPA concludes that the new microorganism is not likely to
present unreasonable risk under the conditions of use.

Potentially Exposed or Susceptible Subpopulation(s) (PESS): EPA considers workers to be a
PESS on the basis of greater exposure potential compared to the general population. EPA also
considers PESS in conducting general population drinking water exposures by evaluating risks
associated with water intake rates for multiple age groups, ranging from infants to adults. EPA
considers consumers of specific products to be a potentially exposed or susceptible
subpopulation on the basis of greater exposure potential compared to the general population who
do not use specific products. For this MCAN microorganism, no use is expected by consumers.
Given the low hazard of the new microorganism, EPA finds that it is not likely to present
unreasonable risk to any PESS.

8/27/18		/s/	

Date:	Jeffery T. Morris, Director

Office of Pollution Prevention and Toxics

3 A microorganism is considered to be of low ecological hazard if it is not known to be an animal or plant pathogen,
and the genetic modifications do not impart pathogenic or toxigenic traits, and the introduced genetic material does
not provide a selective growth advantage in outcompeting indigenous microbial communities in the environment.


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