Interim Evaluation of the VCCEP Pilot and Proposed Modifications
- Stakeholder Feedback on Initial Proposal for VCCEP Modifications
- Revisions to Proposed Modifications of VCCEP
On November 20, 2006, EPA issued a Federal Register notice requesting comment on the implementation of the VCCEP pilot phase. The notice included a list of questions about which the Agency was particularly interested in receiving feedback. The Agency also requested comments on other aspects of the VCCEP Pilot on which commenters had experience and/or had formed definite opinions. Several organizations and individuals responded to EPA's request for comment on the implementation of the VCCEP pilot. A total of 138 individual comments were compiled and summarized in a document entitled "Summary of Comments on the VCCEP Pilot" (45 pp., 266KB, about PDF). Comments were reviewed by EPA and indicated that significant program changes should be considered.
Stakeholder Feedback on Initial Proposal for VCCEP Modifications
The Agency identified specific modifications to VCCEP that it believed would address the comments received on the VCCEP pilot. These initial, proposed modifications were described in a Federal Register Notice (3 pp., 65KB, about PDF) and presented at a public meeting held on July 22, 2008. The predominant feedback provided to EPA at the public meeting was that the Agency was not going far enough in its contemplated plans to modify VCCEP. Based on this response, EPA reconsidered some of the process steps in VCCEP and has developed an even more thorough set of proposed modifications.
Revisions to Proposed Modifications of VCCEPOn October 3, 2008, EPA e-mailed a document describing EPA's current views on needed modifications (6 pp., 288KB, about PDF) to VCCEP stakeholders along with information on a meeting of EPA's Children's Health Protection Advisory Committee (CHPAC) where they would be discussed. The Committee met October 21-23, 2008, at the Churchill Hotel, Washington, DC. Stakeholders were welcome to attend and observe the discussion. Time was provided on the agenda for public comment, but no comments were made. Additional details on this meeting can be found at agenda1008.doc.
The major points covered in the document reviewed by CHPAC included:
- Future VCCEP candidate chemicals will be selected from those identified as high priority and of special concern for potential risks to children in EPA's Chemical Assessment and Management Program (ChAMP).
- The role of Peer Consultations in VCCEP will be changed in the modified VCCEP. Sponsors may opt to use Peer Consultation when they question the need for data requested by EPA. The Peer Consultation will advise the sponsor on the reasonableness of his position and the strength of his arguments.
- VCCEP assessments at Tiers 2 and 3 will be combined, in most cases, unless the sponsor can develop sound scientific reasons not to do so.
- Time frames will be specified for every step in the VCCEP process.