# More questions for EPA on identifying chemicals for prioritization under TSCA

*Published:* 2017-11-29
*Author:* Lindsay McCormick

[*Lindsay McCormick* ](http://www.edf.org/people/lindsay-mccormick)*is a Project Manager.*

When EPA finalized its framework prioritization rule under TSCA last June, the agency deleted its proposed approach to identifying potential candidate chemicals for prioritization. EDF had [supported EPA’s initial proposed rule](https://blogs.edf.org/health/2017/03/21/getting-the-framework-right-for-the-new-tsca-edf-comments-filed-on-key-epa-proposed-rules/), and EPA’s decision to delay this process to allow for additional stakeholder engagement tracks closely with the comments chemical industry groups submitted on that proposed rule.

EPA is now holding [a public meeting](https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/meetings-and-webinars-amended-toxic-substances-control) on December 11th to discuss its [proposed approaches](https://www.epa.gov/sites/production/files/2017-11/documents/final_pre-prioritization_-_discussion_document_11.13.17.pdf) and get input from stakeholders. As with the upcoming [meeting on new chemical reviews](https://blogs.edf.org/health/2017/11/21/more-questions-than-answers-edf-submits-extensive-questions-to-epa-in-advance-of-public-meeting-on-new-chemical-reviews/), EPA is accepting questions ahead of the meeting.

In response, EDF submitted a number of questions to the agency on Monday, relating to our concerns in the following areas:

- EPA’s stated intention to significantly exceed its statutory minimum of designating 20 low-priority chemicals within the law’s specified timeframe.
- EPA’s passive approach to utilizing its new authorities to fill data gaps on chemicals before they enter the prioritization and risk evaluation processes.
- The need to ensure transparency with respect to health and safety studies and underlying data used by EPA to identify candidate chemicals for prioritization.
- Specific concerns regarding EPA’s proposed approaches, including to utilize Canada’s Chemicals Management Plan as a model and to use EPA’s Safer Chemicals Ingredient List (SCIL) as a basis for identifying low-priority chemicals.

Read our full list of questions [here ](https://blogs.edf.org/health/wp-content/blogs.dir/11/files/2017/11/EDF-Questions_Public-Meeting_Approaches-for-Identifying-Potential-Candidates-for-Prioritization.pdf)for more details.