Comment Submissions - Public Comment Period and Workshops on the Draft Hot Spots Cancer Inhalation Unit Risk Factors for Cobalt and Cobalt Compounds

The Cobalt Institute (CI) is a global, non-profit trade association composed of producers, users, recyclers, and traders of cobalt (Co). We promote the sustainable and responsible production and use of cobalt in all its forms. The CI acts as a knowledge center for governments, agencies, industry, the media and the public on all matters concerning Co and Co containing substances. The current and future societal value of cobalt and its many applications is high. Cobalt is essential to a healthy, safe and modern life. Looking forward, cobalt is a critical raw material that will make a net-zero carbon economy a reality. Equally, the cobalt industry will play a strategic role in the development of a circular economy. As the cobalt industry, we are committed to making the investments needed in our business and our people to deliver this sustainable future. We will continue to commit our time and resources to ensure that our products are produced and used safely, responsibly and sustainably. To reach the goals we share with policymakers, we will work with authorities to ensure a holistic and proportionate approach to the regulation of our products. The US Department of the Interior considers cobalt as “critical to the economic and national security of the United States”. (https://www.usgs.gov/news/interior-releases-2018-s-final-list-35-minerals-deemed-critical-us-national-security-and.) The relevance of cobalt to California’s economy is summarized in the January 2019 report entitled; “A Closer Look at California’s Cobalt Economy”, from The California Centre for Jobs and the Economy. This report is in the public domain and is freely available online (https://centerforjobs.org/wp-content/uploads/A-Closer-Look-At-Californias-Cobalt-Economy-2.pdf). The report concludes that; “California’s policies are leading to an over-reliance, if not complete dependence, on electrification including increasing generation from intermittent sources. This shift will require a significant investment in battery technology—currently dominated by lithium-ion—for a range of transportation and other applications, including storage technology not currently available.” Cobalt is a critical ingredient in all commercially important lithium-ion battery technologies. Furthermore; “Increased demand (for cobalt in batteries) will also put additional pressures on other existing and emerging cobalt applications, including electronics like cellular phones, computers, wheelchairs, medical devices and myriad other battery-powered devices along with traditional uses for metallurgical and other chemical products.” CI’s technical expertise includes Co related health, safety, and environmental issues. We welcome the opportunity to provide technical comments on your document deriving cancer slope factors for Co and Co compounds. Based on a thorough scientific review, we have already submitted preliminary comments in April 2019. These are followed up and complemented today with a more detailed response into the public consultation. In summary, we are concerned that there are four separate very conservative assumptions. Their combination results in a “multiplication of conservatism” that in turn results in a significant overestimation of risk. We thank you for your attention to these comments.