Past Action

Please provide comments to EPA by August 30, 2019 on the Draft Risk Evaluation on HBCD! 
The National Tribal Toxics Council (NTTC) has been preparing comments on the Draft Risk Evaluation on HBCD that EPA released in June 2019. Click here for a template you can use to file public comment on behalf of your tribe on this risk evaluation. NTTC does not think EPA's risk evaluation gives Tribes adequate consideration or protection and, if you agree with NTTC, it is really important for EPA to receive your comments during this public comment period, before the HBCD risk evaluation is finalized. Please note the deadline is this Friday, Aug 30, 2019. Please note that the text in Red in the template is used as instructions on filling out the template. Please replace it with your own words and delete all red text from the final template before submitting. You can submit your comments at In the comment box, you can say "Your Tribe's comments on HBCD draft risk evaluation" then upload your letter by pressing "Choose files". Press "Continue" to submit and you will see a confirmation page when your comment has been submitted. 

Please provide comments to EPA by September 28, 2018 about how important toxic-free water is to your tribe and your tribal lifeways! Your comments matter! 

PFAS has been found in all types of water bodies: Lakes, creeks, rivers, bays, oceans, and ground water. It has been found in municipal drinking water and well water, both treated and untreated. Please see the information sheet here for examples of some of the thousands of products that contain PFAS chemicals, and for the online link about how to submit comments to EPA.

Your tribe’s comments can be as simple as explaining how tribal members interact with water from rivers, creeks, ponds, the ocean, and the faucet. For example,
"Our tribe uses untreated water from a local lake for sweat lodges or steam baths".
"Our tribal members use unmonitored well water for cooking or cleaning."
"Our children swim in water for hours at a time over several summer months."
"Our tribe harvests for food shellfish, eels, and different kinds of fresh water fish, or marine mammals."
"Our tribe has a lot of members that fight fires with retardants"
Or comments can be be more detailed about how tribal members interact with water or soil or products that contain PFAS. You can describe how often and for how long people are conducting these activities that bring them into contact with water or soil that or products that contain PFAS.

Submit Comments Here


Historic Work: Under amended TSCA, tribes meet the definition of an exposed subpopulation, and EPA must adequately and transparently evaluate these exposures, by law. 


The National Tribal Toxics Council submitted to EPA these extensive comments with a sizable number of references to scientific studies demonstrating toxic properties of the chemical HBCD and some of the other 10 chemicals EPA is evaluating. Please read the two-page Executive Summary for issues presented. The full document provides the basis for risks Tribal people face being able to represent risks of other exposed and susceptible subpopulations.
Tribes have high exposure to the natural environment, high dietary reliance on local wild foods, and unique customary and traditional lifeways that are not present in the United States general population. Consequently, they meet the definition of an exposed subpopulation under TSCA, as amended, and EPA must adequately and transparently evaluate these exposures. Yet, tribal-based risk is not addressed in the First Ten Chemical Problem Formulations, and is not even mentioned, whether it be in the literature search or bibliography, the narrative, or conceptual model.
Affirmed by the Supreme Court, it is the law of the land that federal agencies must fulfill a legally-binding trust responsibility to protect tribal trust resources and must uphold U.S.-Tribal treaty agreements. The June 22, 2016 TSCA amendments mandate health-based assessments and the inclusion of sensitive and exposed subpopulations in identifying the health risk of chemicals to the American people.

Click here to see comments submitted by NTTC to EPA 


Tribal Consultation Session on EPA’s Proposed Regulation of Persisent, Bioaccumulative, and Toxic Chemicals under TSCA Section 6(h)  


See this document for more detailed information.  EPA's anticipated timeline for the consultation and coordination period is expected to extend from August 6, 2018, through September 11, 2018. During this period, EPA will conduct two Tribal Consultations (see below).

Thursday, August 30, 2018, Tribal Consultation 1 from 1:00-3:00 pm (EDT)
Call-in Number: 1-866-706-9614 Conference ID number: 6659186 

Thursday, September 6, 2018, Tribal Consultation 2 from 1:00-3:00 pm (EDT)
Call-in Number: 1-866-706-9614 Conference ID number: 9488696


Share Tribal Data – Do you have data to share that can be used to assess tribal risks from chemicals? If so follow the link below.

Click here for information on how to share tribal data



Tribal access to Confidential Information from Businesses on toxic chemicals they use in making products: 30-day EPA comment period ends April 16th 2018! 

See this document for more detailed information.  EPA is developing guidelines for tribes to request confidential business information (or "CBI") at All of the draft documents, including how to identify if the request is made due to an emergency, are available at

Click here for a draft template letter that tribes may use to develop their own comments on the guidelines



EPA Draft Strategic Plan FY18-FY22, comments due 10/31/17

Urgent! The Draft FY 2018-2022 EPA Strategic Plan, is now out for public comment through October 31, 2017.
The Federal Register notice: Federal Register notice
The Draft Strategic Plan: Draft Strategic Plan
Consistent with government-wide requirements, the Strategic Plan establishes the goals, objectives, and measures for achieving positive environmental outcomes over the next four years. This draft Plan is designed to refocus the agency back to its core mission, restore power to the states through cooperative federalism, and lead the agency through process and the rule of law. It captures the key areas the EPA Administrator will emphasize to transform the way the agency does business.





Tribal Consultation Session on EPA’s FY 2018-2019 Draft National Program Manager (NPM) Guidance

This session was led by EPA’s Office of the Chief Financial Officer (OCFO) and was set up to have most of the time dedicated to tribal feedback and an exchange of dialogue. OCSPP management and other EPA Program Offices also participated in the meeting. OCFO  extended the comment period to Friday, August 4th 2017. You can provide written comments regarding OCSPP’s Program to Beth Burchard (, Blair Budd ( and Jennifer Vernon (; please also cc: Cindy Wire (, Edna Kapust ( and Amanda Hauff ( It is requested you use the FY 2018-2019 Draft NPM Guidance External Comments Template. Responses to comments will be posted on August 21st  2017 at EPA’s NPM Guidance website: – you can also find all of the Draft FY 2018-2019 NPM Guidances now available here. Lastly, you will find additional materials being posted to EPA’s Tribal Consultation Opportunities Tracking System ( next week. OCFO plans to post an overview document that captures speaking points from each Program Office from the July 11th Tribal Consultation Session. 

Meeting Logistics: EPA Tribal Consultation Session on FY 2018-2019 Draft NPM Guidance
Date: Monday, July 31, 2017
Time: 2:00pm-4:00pm EST
Phone and Code: 1-866-299-3188; Code: 202-564-3020
Adobe Connect:
Agenda: Click here


January 2017 – Consultation and Coordination on three rulemakings required by the Toxic Substances Control Act (TSCA)




Are you concerned about chemicals in the products you buy – like household cleaners or baby toys? The U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics (OPPT) is initiating a consultation and coordination with federally-recognized Indian tribes on three Toxic Substances Control Act (TSCA) proposed actions that affect the consermer products you may buy:

1) A proposed procedural rule required under section 6 regarding EPA’s process for prioritizing chemicals as either a High- or Low-Priority for further evaluation;

2) A proposed procedural rule required under section 6 regarding EPA’s process for conducting Risk Evaluations on priority chemicals; and,

3) A proposed reporting rule required under TSCA section 8 requiring a one-time notification to  EPA by manufacturers (including importers) if they have manufactured or imported a substance in the past 10 years, that will enable EPA to label “active” and “inactive” chemical subsets of the TSCA Inventory. 

Respond to Open Tribal Consultation until March 14, 2017! Share with EPA your concerns about making sure Tribal populations are appropriately considered in the risk evaluations for these chemicals. EPA has set two Tribal Consultations calls:

Wednesday, February 22, 2017, Tribal Consultation 1 from 1:00-4:00 pm (EDT)
Call-in Number: 1-866-900-8984   Conference ID number: 30653848

Thursday, February 23, 2017, Tribal Consultation 2 from 1:00-4:00 pm (EDT)
Call-in Number: 1-866-900-8984   Conference ID number: 30667674

For a list of talking points for these calls, CLICK HERE

If you are unavailable for these consultation calls and have comments, including written comments, on any of these actions, please send them to Irina Myers at or by U.S. postal service at:

Irina Myers
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics – MC 7408M
1200 Pennsylvania Ave, NW
Washington, DC 20460

Relevant Documents:

TSCA RulesTribal Consultation Letter

TSCA Inventory Active-Inactive Notification – Proposed Rule Summary

Prioritization of Chemicals for Risk Evaluation

Procedures for Chemical Risk Evaluation

NTTC-Understanding Tribal Exposures to Toxics

See EPA's tribal consultation website:





Draft Guidelines for Human Exposure Assessments

Respond to Tribal Consultation until September 12, 2016! Share with EPA your concerns of the larger amount human exposure to chemical agents (stressors) that American Indians and Alaska Natives experience due to longer and more frequent contact with the environment and it's resources. The new guidelines will have far-reaching and long-lasting impacts to measuring the negative effects of chemicals on tribal people and tribal lifeways: lifegiving natural resources gathered and harvested throughout the year.

See EPA's tribal consultation website:

And the documents posted online during the peer review, public comment period:


Draft Guidance for Conducting Fish Consumption Surveys

EPA is initiating tribal consultation on the draft Guidance for Conducting Fish Consumption Surveys for tribal review and comment. This is an update to the 1998 guidance. 

NOTE! Tuesday, August 23, 2016 from 2:00 – 4:00 pm Eastern Time: The ONLY Webinar on Draft Guidance for Conducting Fish Consumption Surveys. To register for the webinar click on the following link: and enter the password Survey$.

And to join the webinar even if you haven't registered, go to:   Simply type your name and click the ‘Enter Room’ button to join the webinar.  You will also need to call in; please dial 1-866-299-3188, conference code 202-566-2083.  

The draft guidance is accessible at


The Toxic Substances Control Act (TSCA), as amended 

Stay updated on EPA activities in implementing the newly amended TSCA!

TSCA is the primary U.S. law for chemicals management, especially chemicals that are in products manufactured or imported for sale in consumer products, such as furniture, paint, cleaning products, clothing, air fresheners, and such.  The new major amendment was passed by Congress and on June 22, 2016, President Obama signed the Frank R. Lautenberg Chemical Safety for the 21st Century Act.  TSCA was originally passed in 1976. 

Meetings on Amended TSCA:

First Year Implementation Plan:  Check out this site to see what EPA has to get done in the first year after the law was signed on June 22, 2016.

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