Comments submitted by Dr. Jennifer McPartland, Senior Scientist, on behalf of Environmental Defense Fund.
Problem Formulations for the Risk Evaluations to be Conducted for the First Ten Chemical Substances under the Toxic Substances Control Act, and Application of Systematic Review in TSCA Risk Evaluations; Notice of Availability
Activity
Environmental Defense Fund filed 3 comments on this docket between Sep 10, 2018 and Sep 12, 2018. 31 other organizations filed here. The comment window closed 2903d ago.
What Environmental Defense Fund filed (3)
Comments submitted by Richard A. Denison, Ph.D., Lead Senior Scientist, on behalf of Environmental Defense Fund (EDF) on Problem Formulations for Risk Evaluations To Be Conducted Under Toxic Substances Control Act. Attached are three documents: Attachment 1: EDF comments on the Ten Problem Formulations Attachment 2: Petitioners Opening Brief challenging EPAs Prioritization and Risk Evaluation Rules (this is Appendix A to Attachment 1) Attachment 3: List of Final and Proposed Superfund Sites (this is Appendix B to Attachment 1)
To Whom It May Concern: Attached are the signatures of 44,954 Environmental Defense Fund supporters from across the country who have commented in strong opposition to your proposal, "Problem Formulations for Risk Evaluations To Be Conducted Under Toxic Substances Control Act, and General Guiding Principles To Apply Systematic Review in TSCA Risk Evaluations." The comment they each submitted reads: "I am writing today gravely concerned about EPA's severely flawed approach to reviewing the risks to health and the environment posed by the first 10 chemicals being evaluated under the newly reformed Toxic Substances Control Act. EPA's decision to ignore many known sources of exposure to the chemicals will severely underestimate their actual threat to public health and will put American lives at risk. This new assault on TSCA implementation is illegal, and flies in the face of the science that informs what we know about how chemicals can affect our health and environment. The science tells us that the combined, long-term, and even low-level exposures resulting from multiple uses and sources of exposure to a chemical are what matters. It is critical that EPA comprehensively assess exposures in order to properly protect the American public from toxic chemicals that we are unknowingly exposed to every day." Please let me know if you have any questions or concerns about the submission of these 44,954 comments. Thank you for your consideration, Heather Shelby Manager, Grassroots Organizing & Activism Environmental Defense Fund hshelby@edf.org
Abstract
Application of Systematic Review in TSCA Risk Evaluations; Notice of Availability
View on regulations.gov →Co-filers (31)
See everyone who commented →- Environmental Defense FundTHIS ORG3 filings · confidence 97%
- Insulators Unionunverified attribution5 filings · confidence 70%
- AFL-CIO3 filings · confidence 97%
- American Chemistry Counciltrade assoc.3 filings · confidence 97%
- American Federation of Statetrade assoc.1 filing · confidence 85%
- American Forest & Paper Associationtrade assoc.1 filing · confidence 97%
- American Petroleum Institutetrade assoc.1 filing · confidence 97%
- American Public Health Associationtrade assoc.1 filing · confidence 85%
- American Water Works Associationtrade assoc.1 filing · confidence 97%
- Association of Global Automakerstrade assoc.1 filing · confidence 85%
- Association of Occupational and Environmental Clinicstrade assoc.1 filing · confidence 85%
- Barber Law Firm on behalf of Albemarle Corporationunverified attribution1 filing · confidence 70%
- California State Universityunverified attribution1 filing · confidence 70%
- City University of New Yorkunverified attribution1 filing · confidence 70%
- Environmental Information Associationtrade assoc.1 filing · confidence 85%
- Environmental Protection Network (EPN)trade assoc.1 filing · confidence 97%
- Household & Commercial Products Associationtrade assoc.1 filing · confidence 97%
- Industrial Minerals Association - North Americatrade assoc.1 filing · confidence 85%
- International Association of Fire Fighterstrade assoc.1 filing · confidence 85%
- International Association of Heat and Frost Insulators and Allied Workerstrade assoc.1 filing · confidence 85%
- Mesothelioma Applied Research Foundationtrade assoc.1 filing · confidence 85%
- National Association of Home Builderstrade assoc.1 filing · confidence 97%
- National Council for Air and Stream Improvementtrade assoc.1 filing · confidence 85%
- National Electrical Manufacturers Associationtrade assoc.1 filing · confidence 85%
- National Tribal Toxics Council (NTTC) - includes mass comment campaign (email)trade assoc.1 filing · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.1 filing · confidence 97%
- On behalf of National Wildlife Federationtrade assoc.1 filing · confidence 85%
- The Endocrine Societytrade assoc.1 filing · confidence 85%
- the International Unionunverified attribution1 filing · confidence 70%
- U.S. Chamber of Commerce1 filing · confidence 97%
- University of Californiaunverified attribution1 filing · confidence 70%
- Utility Workers Union of Americaunverified attribution1 filing · confidence 70%