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).
TSCA Work Plan Chemical Problem Formulation of Cyclic Aliphatic Bromides/ Hexabromocyclododecane (HBCD) Cluster
Activity
Environmental Defense Fund filed 2 comments on this docket between Nov 20, 2015 and Mar 18, 2016. 7 other organizations filed here. The comment window closed 3905d ago.
What Environmental Defense Fund filed (2)
Please find attached Environmental Defense Fund's comments on the TSCA Work Plan Chemical Problem Formulation and Initial Assessment for the Cyclic Aliphatic Bromides Cluster Flame Retardants.
Abstract
During scoping of this assessment’s TSCA related uses, exposures and hazards were identified for Hexabromocyclododecane (HBCD; CASRN 25637-99-4), 1,2,5,6,9,10-Hexabromocyclododecane (1,2,5,6,9,10-HBCD; CASRN 3194-55-6), and 1,2,5,6-Tetrabromocyclooctane (CASRN 3194-57-8). 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 HBCD.
View on regulations.gov →Co-filers (7)
See everyone who commented →- Environmental Defense FundTHIS ORG2 filings · confidence 97%
- Natural Resources Defense Council (NRDC)trade assoc.2 filings · confidence 97%
- Albemarle Corporationunverified attribution1 filing · confidence 70%
- Alliance of Automobile Manufacturerstrade assoc.1 filing · confidence 97%
- American Chemistry Counciltrade assoc.1 filing · confidence 97%
- Center for Biological Diversity1 filing · confidence 97%
- Extruded Polystyrene Foam Associationtrade assoc.1 filing · confidence 85%
- Green Science Policy Institutetrade assoc.1 filing · confidence 85%