Download Pentachlorophenol Task Group: Comments on Development of the Priority Chemicals List, August 11, 2010 (PDF: 69KB/2 pages)

Pentachlorophenol Task Force
205 James Thurber Court
Falls Church, VA 22046
(703) 538-4915 Telephone
(703) 532-1193 Facsimile
[email protected]
E. John Wilkinson
Manager
August 11,2010
(via email: [email protected] )
Minnesota Department of Health
Attn: Lists of Chemicals of High ConcernlPriority Chemicals
Environmental Health Division
Site Assessment & Consultation Unit
POBox 64975
St. Paul, Minnesota, 55164-0975
Re:
Comments on the Development of the Priority Chemicals List
Dear SirlMadam:
The Pentachlorophenol Task Force (Task Force) appreciates the opportunity to comment
on the Minnesota Department of Health recent publication of a list of Chemicals of High
Concern which includes pentachlorophenol. There are a couple of issues that need to be
considered about this listing.
We note that the statute doesn't expressly exclude all pesticides, but does exclude
agricultural use pesticides. We believe that pentachlorophenol should not be included in the list
of chemicals of concern because like the most agricultural use pesticides, it is a restricted use
material only applied to wood products in industrial settings. The primary use is for treatment of
utility poles. Thus, it is unlikely that products treated with pentachlorophenol would pose a
significant exposure pathway for children. We believe that restricted use pesticides that are not
used on products intended
for use by children should be excluded from the list of CHCs along
I
with agricultural use pesticides.
The second issue is whether pentachlorophenol meets the PBT requirements of the
statute. The Minnesota Chemicals of High Concern Methodology Document contains the
following information about this requirement:
"The statute indicates that CHC chemicals need to be "known or suspected with a high
degree of probability" to cause health effects or be a chemical that is persistent, bioaccumulative
and toxic (PBT) or very persistent and very bioaccumulative (vPvB). Because "high degree of
probability" was not defined, MDH needed to establish a guideline for this determination when
reviewing chemicals. Ideally, a full process for chemical evaluation would have been developed,
but this was not possible with the time and resources available. MDH therefore relied on work
done by other agencies for determining likelihood of a chemical to cause harm."
Minnesota Department of Health
August 11, 2010
Page 2
Later on, in the section on "Persistent, Bioaccurnulative and Toxic Chemicals" there is a
discussion of the various criteria that different agencies have established for persistence,
bioaccumulation and toxicity. It was also noted that there had not been time for Minnesota to
consider the available information for each chemical on the list.
The Task Force would like to note that the United Nations Economic Commission for
Europe (UNECE) of which the US and Canada are members recently determined that
pentachlorophenol did not meet the criteria for listing under the Persistent Organic Pollutant
Protocol of their Long-range Transboundry Air Pollution Convention. In particular, it did not
meet the bioaccurnulation criteria. Also, USEPA has recently reviewed pentachlorophenol under
Reregistration and concluded that "The results of the guideline study agree with those found in
the literature in that the BCF's were generally less than 1000 and the depuration of residues was
rapid.,,1 The Task Force believes that because of these findings, based on the criteria in the
statute, pentachlorophenol should not be listed as a Chemical of High Concern.
Please contact us if you have any questions about the information presented in these
comments and we appreciate your consideration of this additional information.
Respectfully submitted,
f· :ftt.-kJ~
E. John Wilkinson
1 EPA-HQ-OPP-2004-0402-0108, February 25,2008. Available at www.regulations.gov