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Panel Letter to EPA on the SACC Peer Review Process 

The American Chemistry Council (ACC) Formaldehyde Panel appreciates the opportunity to provide additional scientific and legal comments on EPA’s December 26, 2023 Federal Register solicitation of nominees and notice of forthcoming peer review (the Notice) including an ad hoc Science Advisory Committee on Chemicals (SACC) review of its draft risk evaluation of formaldehyde under Section 6 of the Toxic Substances Control Act (TSCA) as well as formaldehyde review under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in 2024. While we await details on other planned actions from EPA discussed in its December 26 notice, this letter identifies key issues for the forthcoming peer review and includes several Panel recommendations, including critical charge questions, to ensure a robust, independent peer review process consistent with TSCA, FIFRA, the Federal Advisory Committee Act (FACA), and EPA policies and guidance.

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Toxic Substances Control Act Formaldehyde
American Chemistry Council

The American Chemistry Council’s mission is to advocate for the people, policy, and products of chemistry that make the United States the global leader in innovation and manufacturing. To achieve this, we: Champion science-based policy solutions across all levels of government; Drive continuous performance improvement to protect employees and communities through Responsible Care®; Foster the development of sustainability practices throughout ACC member companies; and Communicate authentically with communities about challenges and solutions for a safer, healthier and more sustainable way of life. Our vision is a world made better by chemistry, where people live happier, healthier, and more prosperous lives, safely and sustainably—for generations to come.