On Tuesday, February 13, 2024, EPN submitted comments on EPA’s draft risk evaluation for tris(2-chloroethyl) phosphate (TCEP). We generally agree with the findings of EPA’s draft risk evaluation and the approaches taken to derive subsequent risk characterizations, provided they have been vetted and validated. However, we suggest EPA develop aggregate exposure assessments and risk estimates for every chemical’s condition of use (COU). We also feel that high-profile, high-priority substances should be subject to publicly staged, collaborative peer review and recommend EPA finalize a generic systematic review protocol applicable to all Toxic Substances Control Act chemicals.
Read the comments.