Tetrachlorvinphos (TCVP): Registration Review Docket

Attached please find the comments of the Natural Resources Defense Council (NRDC). Remedy of the flaws in the Draft Risk Assessment will identify exposures which do not meet the safety standard. We urge EPA to fill the remaining gaps in this assessment and initiate proceedings to cancel all pet uses for tetrachlorvinphos (TCVP). Although this DRA improves upon the November 6, 2014 Residential Exposure Assessment, it continues to underestimate risks to children from TCVP-containing pet products by, among other things, utilizing unsubstantiated algorithms and assumptions, and failing to consider dermal exposure, which in previous assessments was found to contribute substantially to a child's risk. Thank you for the opportunity to provide these comments. We look forward to working with you to ensure the safety of pet products. Sincerely, -Miriam Rotkin-Ellman, MPH Senior Scientist Natural Resources Defense Council