Environmental Defense Fund filed 2 comments on this docket between Nov 20, 2015 and Mar 18, 2016. 6 other organizations filed here. The comment window closed 3905d ago.
Environmental Defense Fund (EDF) strongly supports EPA's efforts to assess chemicals through the TSCA Work Plan Chemical Program, including several clusters of flame retardant chemicals. We appreciate the opportunity to comment on the Problem Formulation and Data Needs Assessment and related documents for the Brominated Phthalates Cluster (BPC).
Please find attached Environmental Defense Fund's comments on the TSCA Work Plan Chemical Problem Formulation and Initial Assessment for the Chlorinated Phosphate Ester Cluster Flame Retardants.
During scoping of this assessment EPA/OPPT identified a structurally related cluster of chlorinated phosphate ester used as flame retardant (CPE FR) chemicals, including tris(2-chloroethyl) phosphate (TCEP, CASRN 115-96-8), 2-Propanol, 1-chloro-, phosphate (TCPP, CASRN 13674-84-5), and 2-Propanol, 1,3-dichloro-, phosphate (TDCPP, CASRN 13674-87-8). This Problem Formulation Assessment describes the TSCA related uses that were evaluated for inclusion and exclusion in this assessment. This problem formulation includes the conceptual model and the analysis plan for evaluating those uses for these chlorinated phosphate ester flame retardants. This analysis plan of CPE TSCA flame retardant uses, also identified best available data and approaches for assessing exposures and hazards.
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