Comment submitted by Robert Simon, American Chemistry Council

October 31, 2006 Document Control Office (7407M) Office of Pollution Prevention and Toxics (OPPT) Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460?0001 Attention: Docket ID Number EPA?HQ?OPPT?2006?0794. On behalf of the American Chemistry Council (The Council) and its Chlorine Chemistry Division, we appreciate the opportunity to provide input on the documents and issues expected to be discussed at the second meeting of the POPs Review Committee (POPRC) under the Stockholm Convention on Persistent Organic Pollutants (POPs). These comments relate to the following POPRC documents and issues: 1. Consideration of proposals for five new chemicals to be considered for addition to the Convention at the November 2006 POPRC meeting. 2. Consideration of draft risk profiles for chemicals previously proposed in November 2005 for addition to the Stockholm Convention. 3. Listing of chemicals the transformation products of which are chemicals proposed for listing in Annexes A, B or C of the Convention. 4. Standard work plan for the preparation of a draft risk profile and a draft risk management evaluation. 5. Draft risk management evaluation outline. 6. Confidentiality arrangements. The American Chemistry Council was significantly engaged in the negotiations of the Stockholm Convention, and we remain committed to its rational implementation. We offer the attached comments to help clarify and improve the quality of the POPRC?s work and to inform the U.S. government?s position for the upcoming POPRC meeting. If there are any questions regarding these comments, please contact Robert Simon at robert_simon@americanchemistry.com or 703-741-5866.