Environmental Defense Fund submits these comments on EPA's Draft Revision to the Toxic Substances Control Act Risk Determination for HBCD.
Toxic Substances Control Act (TSCA) Science Advisory Committee on Chemicals (SACC) - Review of Risk Evaluation for Cyclic Aliphatic Bromide Cluster (HBCD)
Activity
Environmental Defense Fund filed 4 comments on this docket between Jul 23, 2019 and Mar 8, 2022. 24 other organizations filed here. The comment window closed 1607d ago.
What Environmental Defense Fund filed (4)
Filed on regulations.gov — full text not in the inline record.
Please find attached comments submitted by Robert Stockman, Senior Attorney, on behalf of Environmental Defense Fund. Attachment 1: Comments on HBCD Draft Risk Evaluation Attachment 2: EDFs comments on the problem formulations for the first 10 chemicals undergoing risk evaluations (Appendix A) Attachment 3: Petitioners Opening Brief (Appendix B) Attachment 4: Petitioners Reply Brief (Appendix C)
Please find attached comments submitted by Lindsay McCormick, Chemicals and Health Program Manager, on behalf of Environmental Defense Fund. EDF previously submitted these comments on the problem formulations for the first 10 chemicals undergoing risk evaluations under TSCA on August 16, 2018. In order to assist the SACC in identifying those comments specific to HBCD, we have attached a cover sheet that identifies each concern and the sections and page numbers where we address that concern in the full set of comments.
Abstract
The TSCA Science Advisory Committee on Chemicals (SACC) will review and comment on the EPA risk evaluation for Cyclic Aliphatic Bromide Cluster (HBCD).
View on regulations.gov →Co-filers (24)
See everyone who commented →- Environmental Defense FundTHIS ORG4 filings · confidence 97%
- American Chemistry Counciltrade assoc.7 filings · confidence 97%
- Environmental Protection Network (EPN)trade assoc.3 filings · confidence 97%
- Southern Environmental Law Center (SELC)2 filings · confidence 97%
- Ad-Hoc Downstream Users Coalitiontrade assoc.1 filing · confidence 85%
- AFL-CIO1 filing · confidence 97%
- Alliance for Automotive Innovationtrade assoc.1 filing · confidence 97%
- Alliance of Automobile Manufacturerstrade assoc.1 filing · confidence 97%
- Chemical Users Coalitiontrade assoc.1 filing · confidence 85%
- Earthjustice1 filing · confidence 97%
- Eastman Chemical Companyunverified attribution1 filing · confidence 70%
- EPS Industry Alliancetrade assoc.1 filing · confidence 85%
- Extruded Polystyrene Foam Associationtrade assoc.1 filing · confidence 85%
- Fragrance Creators Association (FCA) and Society of Chemical Manufactures and Affiliatestrade assoc.1 filing · confidence 85%
- Fragrance Science & Advocacy Counciltrade assoc.1 filing · confidence 85%
- National Association of Home Builderstrade assoc.1 filing · confidence 97%
- National Tribal Toxics Counciltrade assoc.1 filing · confidence 85%
- National Tribal Toxics Council (NTTC) - includes mass comment campaigntrade assoc.1 filing · confidence 85%
- Natural Resources Defense Council (NRDC)trade assoc.1 filing · confidence 97%
- Plastics Industry Associationtrade assoc.1 filing · confidence 85%
- the International Unionunverified attribution1 filing · confidence 70%
- the Motor & Equipment Manufacturers Associationtrade assoc.1 filing · confidence 85%
- Toxic Use Reduction Institutetrade assoc.1 filing · confidence 85%
- TSCA Against Whole Chemical Approach Coalitiontrade assoc.1 filing · confidence 85%
- University of Californiaunverified attribution1 filing · confidence 70%