Comment submitted by Terry Medley, Global Director, Corporate Regulatory Affairs, DuPont and Scott Walsh, Project Manager, Corporate Partnerships, Environmental Defense, Environmental Defense and DuPont Partnership

September 7, 2007 The Environmental Defense and DuPont Partnership wish to submit our June 21, 2007 Nano Risk Framework as a public comment in response to EPA?s "Concept Paper for the Nanoscale Materials Stewardship Program under TSCA" and "TSCA Inventory Status of Nanoscale Substances ? General Approach," which were noticed in the Federal Register on July 12, 2007. (Docket# EPA-HQ-OPPT-2004- 0122). In this joint submission, we take no position regarding EPA's proposal for a Nanoscale Materials Stewardship Program (NMSP) or its approach to determining the TSCA Inventory status of nanoscale substances. (Each organization will address the NMSP and TSCA Inventory status papers in individual comments submitted independently to the Agency.) Rather, we believe that aspects of the Nano Risk Framework may be useful to EPA with respect to any of the actions it may undertake to address potential risks of nanoscale materials and establish oversight measures for the responsible development of nanoscale materials. These aspects include: ? The application of a lifecycle approach to addressing nanomaterial risks, including the development of profiles addressing the properties, hazard and exposure potential of nanoscale materials across their full lifecycles. ? The adaptation of the traditional risk management framework to account for novel or unique features of nanoscale materials and their applications. ? The framework's approach to developing robust information about nanomaterials and applications in advance of their commercialization. ? The elaboration of a process whereby risk evaluations and management decisions are to be revisited and revised in light of new information or changing conditions, which can in turn identify new information and risk management needs. ? The call for transparency and accountability mechanisms to be incorporated into management systems. ? The articulation of base sets and additional data elements in the areas of physical-chemical characterization, safety hazards, health hazards, environmental fate, environmental hazards, and exposure measurement, monitoring and mitigation. We appreciate the opportunity to provide this public comment. Terry Medley Scott Walsh Global Director, Project Manager, Corporate Regulatory Affairs Corporate Partnerships DuPont Environmental Defense 1007 Market Street 1875 Connecticut Ave, NW, Wilmington, DE 19898 Washington, DC 20009 302-773-3191 202-387-3500 terry.l.medley@usa.dupont.com swalsh@environmentaldefense.org Attachment ? Environmental Defense-DuPont Nano Risk Framework