IMA-NA filed comments with the U.S. EPA to help establish the scope of risk evaluations under development for ten chemical substances designated for priority risk evaluation under the recently reformed Toxic Substances Control Act, specifically relative to “asbestos.” EPA asked the public for assistance in identifying information related to conditions of use (i.e., intended, known or reasonably foreseen uses) that would assist the Agency in identifying potential exposure scenarios (pathways, routes and populations). “Asbestos” is a generic term, referring to certain silicate minerals of a particular chemistry and crystalline growth habit, in contrast to certain common silicate minerals with the same chemical formula but a nonasbestiform growth habit. IMA-NA stressed adherence to good mineral science and urged EPA to focus of its risk evaluations for “asbestos” on the six regulated forms of commercial asbestos. Evidence that EPA placed in the record to support the scope of its risk evaluations misstated that certain products contained asbestos, when they in fact contained the nonasbestiform analog.
IMA-NA’s comments are posted below.