Dear Assistant Administrator Freedhoff: The organizations signing on to this request appreciate the opportunity to comment on the referenced proposal issued by the Environmental Protection Agency.
Chlorine chemistry is an integral part of the goods and products Americans use every day. The computer screen – or paper – on which you are reading this letter was made using products that are derived from chlorine and co-product sodium hydroxide chemistry. The chlor-alkali process, which utilizes chrysotile asbestos safely to manufacture chlorine and sodium hydroxide, or caustic soda, is also used to treat drinking water. In addition to water treatment, chlorine from this same process helps to ensure the safety of consumer goods, medical equipment, medications, and other life-enhancing products. We, the undersigned organizations, urge you to reconsider the need for the U.S. to transition completely away from targeted and safe uses of chrysotile asbestos in the proposed Toxic Substances Control Act (TSCA) Risk Management Rule. An abrupt ban would affect one-third of America’s chlorine capacity and impact many industries. It would also affect a large number of chemical manufacturing sites using sheet gaskets across the country that would additionally impact supply of other needed chemistries to downstream users. At a time when the United States is facing inflation and supply chain issues, we respectfully urge the Biden-Harris Administration not to risk severely reducing the ability of Americans to have access to clean drinking water and essential products that rely on chlorine.