Attachment 7

October 18, 2021

Michal Freedhoff, Ph.D.
Assistant Administrator
Office of Chemical Safety and Pollution Prevention
U.S. Environmental Protection Agency
1201 Constitution Avenue NW
Washington, DC 20004
Dear Dr. Freedhoff:
On behalf of the California Department of Toxic Substances Control’s (DTSC) Safer
Consumer Products (SCP) Program, I appreciate the opportunity to comment on docket
EPA-HQ-OPPT-2017-0652 regarding the proposed renewal of the EPA’s Information
Collection Request related to expanded access to Toxic Substances Control Act
(TSCA) Confidential Business Information (CBI).
DTSC believes that expanded access to TSCA CBI has the potential to be very valuable
to the Safer Consumer Products Program, California as a whole, and programs in other
state addressing toxic chemicals in products. Access to TSCA CBI, in specific
instances, may greatly assist the SCP Program in identifying consumer products that
contain potentially harmful chemicals and promoting the development, sale, and use of
safer alternatives to those chemicals.
DTSC also believes that EPA’s estimated total annual burden (89 hours) and estimated
total annual costs ($5,873.98) to prepare the required agreements and statements to
satisfy the conditions for access to TSCA CBI are reasonable. These costs are minimal
and trivial relative to the expected benefits to the SCP Program of access to TSCA CBI
in certain cases.

Printed on Recycled Paper

Dr. Michal Freedhoff
October 18, 2021
Page 2
Thank you for considering the potential impacts on state, tribal, and local governments;
environmental, health, and medical professionals; and emergency responders of the
anticipated effort required to gain expanded access to TSCA CBI.
Sincerely,

Karl Palmer
Deputy Director
Safer Consumer Products Program
Department of Toxic Substances Control
California Environmental Protection Agency
cc:

Jessica Barkas, PMOD, EPA OPPT
Office of Chemical Safety and Pollution Prevention
U.S. Environmental Protection Agency
1201 Constitution Avenue NW
Washington, DC 20004
Andre Algazi
Branch Chief
Department of Toxic Substances Control
Safer Consumer Products Program
1001 I Street, P.O. Box 806
Sacramento, California 95814-0806
Topher Buck
Senior Environmental Scientist Specialist
Department of Toxic Substances Control
Safer Consumer Products Program
1001 I Street, P.O. Box 806
Sacramento, California 95814-0806