3/ 26/ 2003 Questions for External Peer Reviewers 1. Do you perceive any significant problems with any of the proposed protocols or test methods that would jeopardize evaluation of coating efficacy?

Background: EPA recognizes that the performance of coatings on wood substrates is a complex phenomenon, and several pre pilot tests would normally be employed to reveal flaws in the test plan that may not surface until well into the study. This is particularly true of the chamber accelerated weathering tests where shrinking and swelling of the ends or exposed surfaces of the coupons may cause splitting and subsequent leaching onto the test surfaces. Can the panel recommend specific test parameters ( chamber temperature, UV light intensity, precipitation cycles, etc.,) that would maximize the potential for evaluating the effects of weathering factors on the coatings yet minimize the chance of unnaturally damaging the coating or substrate?

2. Does the selection criteria of the coating screening study provide the correct coating candidates for the larger weathering study? If not, what should be changed?

Background: There is little published data that demonstrates the initial level of arsenic reduction provided by a coating. The screening step may or may not provide insight into rank order of the various coatings and/ or rank order of coating classes on initial application. Further, initial apparent efficacy may have little or nothing to do with longer term performance with weathering. In light of these potential shortcomings, does it make sense for EPA to inform the selection of coatings process with rank order determined by the screening study?

3. How should EPA deal with coatings that require or recommend a multiple coating system ( e. g. primer, coating)?

Background: Some products recommend a multiple coat system.. Should EPA evaluate products that recommend multiple coatings?

4. Are the mini decks a sound approach to evaluation of performance in the field?

Background: In the real world, playground structures, picnic tables, decks etc., are fastened together with nails and screws. The structure undergoes stresses from use as well as weathering and these stresses may cause failure of the coating system at the joints and fastening points. What size deck would the panel recommend to capture the stresses that might be expected? 5. How long does the panel recommend that the mini deck field trial last?

Background: The accelerated weathering chambers are expected to provide measurable performance separation between products or classes of products. Does the panel feel that the out of doors weathering experiments will provide useful information within six months?

6. Should EPA standardize test coupon size between the chamber and out ofdoors weathering experiments?

Background: Surface to volume and end cut to length ratios may impact the interactions between the coating and the substrate. EPA has chosen to use 5/ 4 X 6" decking in the lab and field studies with board lengths of about 30 cm in the chambers and about 90 cm in the field tests. Does the panel feel that this poses a serious risk to comparison of the chamber and out of doors experiments?

7. Which is the better approach to establish baseline: 1) sampling the specimens on the surface to be coated and subsequently correcting for the arsenic removed before coating; or 2) coat specimens whose surfaces have never been rubbed and establishing baseline on contiguous specimens?

Background: The amount of arsenic measured by wipe sampling varies along the length of a board and from front to back. The " baseline" concentration of arsenic available for contact at the surface prior to coating can be determined by wiping the surface prior to coating or by wiping adjacent surfaces. Wiping a surface to be coated before coating provides a direct measure of the dislodgeable amount on the surface prior to coating but also removes that amount from the surface. Thus, if a coating is applied over a surface that has been wiped, one must estimate the reduction due to " wiping effect" by sampling non coated, non weathered boards a second time. This approach to determination of baseline does not consider that the application process as well as possible interactions between the coating and the treated wood may impact the residue level.

8. EPA proposes to use deck boards of 6" nominal width in all the coatings evaluations. The CPSC wipe device is 3.5" in diameter. This means that the arsenic on each side of the wipe will not be removed by the wipe procedure at each sampling event. Can this confound analysis of the data? Should EPA use coupons of the same width as the wipe device or modify the width of the wipe?

Background: There are two potential confounders related to this question. First of all, the wipe procedure may be considered a form of abrasion. The study design does not have a control for this factor except that the proposed mini decks have one set of boards that are only wiped at the final sampling period. Secondly, if only a portion of a board is wiped, contaminants from the non wiped area may be washed onto the wiped area by precipitation or condensation run off. For the purposes of the study, does it make more sense to reduce the width of the test boards ( at the risk of exaggerating surface/ volume effects), alter the wipe sampling device, or institute some other control measure?

9. How will the decision to only determine arsenic concentrations impact the usefulness of the data?

Background: The study design determines arsenic but not chromium or copper. The decision to focus on arsenic was due to several factors: ( 1) resource limitations, ( 2) toxicity potential ( most sensitive cancer endpoint) and ( 3) potential confounder for chromium. The weathering chambers are manufactured from aluminum and stainless steel. Stainless steel contains significant amounts of chromium. EPA has no data at this point to evaluate potential chromium contamination from the chamber. One could argue that EPA should monitor chromium  if for no other reason than to characterize the long term performance of the chambers. How crucial is chromium data? To the evaulation of coatings performance, to characterization of the CCA wood substrate, to evaulation of the test chambers and the overall protocol?


Facility Size ( facsize. sd2)

MP& M facility size based on discharge flow.

Data Element Definitions SITEID  Facility site identification number ( CBI: these have been masked) SITEDEST  Facility discharge type ( indirect = I, direct = D) WEIGHTS  Facility weight FACFLOW  Facility flow in millions of gallons per year SIZE  Facility size based on annual flow


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Marjorie: Here is the UVB 1st paragraph, as requested.

Atmospheric ozone absorbs a harmful band of ultraviolet radiation from
the sun called UV-B, providing a protective shield to the Earth's
surface.  The majority of this protection occurs in the stratosphere
where 90% of atmospheric ozone is located.  The remaining 10% of the
Earth's ozone is present at ground level (referred to as tropospheric
ozone) (NAS, 1991; NASA ).  Only  a portion of the tropospheric fraction
of UV-B shielding is from anthropogenic sources (e.g., power plants,
byproducts of combustion). The portion of ground level ozone associated
with anthropogenic sources varies by locality and over time.  Even so,
it is reasonable to assume that reductions in ground level ozone would
lead to increases in the same health effects linked to in UV-B
exposures.  These effects include fatal and nonfatal melanoma and
non-melanoma skin cancers and cataracts.   The values of $15,000 per
case for non-fatal melanoma skin cancer, $5,000 per case for non-fatal
non-melanoma skin cancer, and $15,000 per case of cataracts have been
used in analyses of stratospheric ozone depletion (U.S. EPA, 1999.
Fatal cancers are valued using standard VSL estimates.  UV-B has also
been linked to ecological effects including damage to crops and forest.
For a more complete listing of quantified and unquantified UV-B
radiation effects, see Table G-4 and G-7 in the Benefits and Costs of
the Clean Air Act, 1990-2010 (U.S. EPA, 1999.  UV-B related health
effects are also discussed in the context of stratospheric ozone in a
2006 report by ICF Consulting, prepared for the U.S. EPA .

Margo Schwab

Statistical and Science Policy
Office of Information and Regulatory Affairs
Office of Management and Budget
Email<EMAIL_ADDRESS>Phone:<PHONE_NUMBER>

-----Original Message-----
From<EMAIL_ADDRESS><EMAIL_ADDRESS>Sent: Thursday, July 12, 2007 1:00 PM
To: Johansson, Robert
Cc: Schwab, Margo<EMAIL_ADDRESS><EMAIL_ADDRESS>Subject: Your proposed footnote language on PM expert elicitation

Margo/Rob:

Attached below, pls find Lisa Conner's recommended edits to the language
you asked us to add to the footnote.
Our question about the last sentence is:  why is it needed?

FN #3: As discussed in Chapter 6, one way in which we characterize the
model uncertainty associated with the relationship between particulate
matter and premature mortality was to conduct an expert elicitation.
The elicitation yielded twelve different functions, generated by asking
12 experts a structured set of questions, leading each to articulate a
functional form for the relationship, in a probabilistic estimate of
uncertainty.  Among the twelve experts, Expert K's function
characterizes the weakest relationship between PM and premature
mortality, whereas Expert E's function characterizes the strongest
relationship.

Marjorie C. Jones
Office of Air Quality Planning & Standards Air Benefit and Cost Group,
Mail Code C439-02 Health and Environmental Impacts Division RTP, NC
27711
voice:<PHONE_NUMBER>
fax:<PHONE_NUMBER>

Shipping/receiving: 4930 Old Page Rd.
Durham, NC 27709

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We are fine with these edits.  The footnote is needed because this
paragraph is in Chapter 8, whereas the discussion of the elicitation is
in Chapter 6.  By the same token, the last sentence is needed so that
readers know why you are referring to Experts E and K - as in, why these
experts?  By saying they represent the bounds on the range of the 12 you
are providing that information.  I think that it is clearer to say
succinctly state that one is the weakest and one is the strongest than
to explain the concept of bounding and what is being bounded in a
footnote.

Margo Schwab

Statistical and Science Policy
Office of Information and Regulatory Affairs
Office of Management and Budget
Email<EMAIL_ADDRESS>Phone:<PHONE_NUMBER>

-----Original Message-----
From<EMAIL_ADDRESS><EMAIL_ADDRESS>Sent: Thursday, July 12, 2007 1:00 PM
To: Johansson, Robert
Cc: Schwab, Margo<EMAIL_ADDRESS><EMAIL_ADDRESS>Subject: Your proposed footnote language on PM expert elicitation

Margo/Rob:

Attached below, pls find Lisa Conner's recommended edits to the language
you asked us to add to the footnote.
Our question about the last sentence is:  why is it needed?

FN #3: As discussed in Chapter 6, one way in which we characterize the
model uncertainty associated with the relationship between particulate
matter and premature mortality was to conduct an expert elicitation.
The elicitation yielded twelve different functions, generated by asking
12 experts a structured set of questions, leading each to articulate a
functional form for the relationship, in a probabilistic estimate of
uncertainty.  Among the twelve experts, Expert K's function
characterizes the weakest relationship between PM and premature
mortality, whereas Expert E's function characterizes the strongest
relationship.

Marjorie C. Jones
Office of Air Quality Planning & Standards Air Benefit and Cost Group,
Mail Code C439-02 Health and Environmental Impacts Division RTP, NC
27711
voice:<PHONE_NUMBER>
fax:<PHONE_NUMBER>

Shipping/receiving: 4930 Old Page Rd.
Durham, NC 27709