Sep 12, 2018· Comment submitted by Jennifer Sass, Senior Scientist, Natural Resources Defense Council (NRDC)· EPA-HQ-OPPT-2018-0314-0022
Attached, please find NRDC comments on EPA TSCA Systematic Review as applied to the Five PBT Chemicals. In summary, NRDC comments detail the serious flaws and industry-bias in the systematic review method used by the EPA to evaluate the five PBT chemicals. The TSCA Systematic Review document is less about evaluating the quality of evidence, and more about eliminating it altogether. The document is incomplete, inconsistent with the state of the science, and too flawed to be used. Accordingly, use of the document is arbitrary and capricious.