In preparing the Exposure Assessment, what are my responsibilities concerning the reporting of exposures outside the chain of commerce?
In a letter dated June 22, 2001 from Stephen L. Johnson, EPA’s Acting Assistant Administrator for the Office of Prevention, Pesticides and Toxic Substances, to Sandra L. Tirey, Assistant Vice President of the American Chemistry Council Mr. Johnson clarified these responsiblities: “For Tier 1 of VCCEP, which is the initial focus of the pilot, we believe that sponsors should do the best that they can in developing a screening level assessment of readily available exposure information, including, to the extent possible, data on exposures outside the chain of commerce. It is important at Tier 1, to put the totality of exposures into context, so that a judgement can be made as to whether the risks a chemical may pose to children have been adequately characterized and hence whether a chemical should proceed to a higher VCCEP Tier. If chemicals proceed beyond Tier 1, EPA stands ready to assist sponsors in the development of more sophisticated exposure assessments addressing outside the chain
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