Publication Summary

Since 1998, the Washington State Department of Ecology has proposed three lists or listing processes of persistent, bioaccumulative toxins (PBTs) with varying degrees of supporting information. The primary focus of this document is the public comments submitted to Ecology in March 2001 on Appendix E of the Proposed PBT Strategy (December 2000).

Since 1998, the Washington State Department of Ecology (Ecology) has proposed three lists or listing processes of persistent, bioaccumulative toxins (PBTs) with varying degrees of supporting information:

1. In August 1998, Ecology distributed a proposed list that included 27 persistent, bioaccumulative, toxic chemicals. This list was developed by the Ontario Ministry of Environment in 1994. Under the 1998 proposal, the list was designed to identify those chemicals that Ecology believed should be virtually eliminated from Washington sources.

2. Ecology received numerous comments on this proposal and elected to make significant changes prior to releasing a Draft PBT Strategy for public review in August 2000. In particular, Ecology proposed to initially focus on 9 of the 12 PBT chemicals identified by the U.S. Environmental Protection Agency (EPA) in the National PBT Strategy.

3. Ecology proposed to identify additional PBT chemicals using the Waste Minimization Prioritization Tool (WMPT) and information on environmental concentrations and releases. Ecology evaluated a list of 66 chemicals identified in the WMPT as having a "PBT characteristics score" of 7, 8, or 9. The approach is outlined in Appendix E of Ecology′s Proposed PBT Strategy (December 2000) that was submitted to the Washington State Legislature for approval and funding in January 2001.

The primary focus of this document is the public comments submitted to Ecology in March 2001 on Appendix E of the Proposed PBT Strategy (December 2000). When evaluating those comments and preparing responses, Ecology has also considered comments received on the Draft PBT Strategy (August 2000) that are relevant to identifying and ranking PBT chemicals. Ecology reviewed both sets of comments and identified (1) the programmatic issue areas listed above and (2) issues and concerns associated with specific chemicals or chemical groups. For each group of comments, Ecology has summarized the relevant portions of the Proposed PBT Strategy and summarized the comments related to that issue. Where multiple comments were received on a particular issue, an attempt was made to summarize each of the major concerns and provide examples of individual comments.

Ecology received numerous public comments on the proposed PBT chemical list and methods for amending that list that were distributed in August 2000 and the revised approach distributed for review in January 2001. Not surprisingly, the opinions on this topic varied widely, reflecting substantial disagreement on the relative merits and reliability of various approaches for identifying PBT chemicals.