IN SEPTEMBER 2003, CLARIANT NOTIFIED EPA THAT IT HAD DISCOVERED INADVERTENTLY-MANUFACTURED PCBs AT LEVELS OVER 50ppm IN TWO RED PIGMENT PRODUCTS. THE PRODUCTS HAD BEEN MANUFACTURED, DISTRIBUTED IN COMMERCE TO CUSTOMERS AND USED IN THE MANUFACTURE OF CONSUMER PRODUCTS FROM EARLY 2002 TO SEPTEMBER 2003. IN ALL, CLARIANT PRODUCED 67 BATCHES OF PIGMENTS AT LEVELS OVER 50ppm IN 2002 AND 2003, AND MADE 129 SHIPMENTS OF PIGMENTS TO CUSTOMERS. AFTER NOTIFYING EPA OF THE HIGH PCB LEVELS IN ITS PIGMENTS, CLARIANT RECALLED UNUSED PIGMENTS FROM ITS CUSTOMERS AND AGREED TO UNDERTAKE A RISK ASSESSMENT OF CONSUMER PRODUCTS CONTAINING ITS CONTAMINATING PIGMENTS. THE RISK ASSESSMENT ANALYZED THE RISKS PRESENTD BY CARPETS AND PLASTIC FOOD WRAP THAT USED THE RED PIGMENT IN QUESTION (THESE WERE DEEMED TO BE THE PRODUCTS WITH THE MOST POTENTIAL FOR HUMAN EXPOSURE). THE PURPOSE OF THE RISK ASSESSMENT WAS TO EVALUATE HETHER PRODUCT RECALLS WERE NECESSARY. THE RECENTLY CONDUCTED ANAYSIS HAS BEEN REVIEWED AND APPROVED BY EPA, AND FINDS THAT THERE IS NO UNREASONABLE RISK FOR END USERS. ACCORDINGLY, PRODUCT RECALLS APPEAR UNNECESSARY.