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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