EPN Comments on EPA’s Proposed Approach for Considering Cumulative Risk Under TSCA

On April 28, 2023, EPN submitted comments responding to EPA’s “Draft Proposed Principles of Cumulative Risk Assessment under the Toxic Substances Control Act” and comments on its “Draft Proposed Approach for Cumulative Risk Assessment of High-Priority Phthalates and a Manufacturer-Requested Phthalate under the Toxic Substances Control Act (TSCA).” The first document details a set of principles for evaluating the cumulative risk of substances under TSCA; the second document presents a proposed approach for applying those principles to the evaluation of the cumulative risk posed by certain phthalates currently undergoing TSCA section 6 risk evaluation. While EPN commends the agency’s adoption of a cumulative risk assessment approach, which will help to more appropriately evaluate risks people face and may be helpful in more effectively mitigating the identified unreasonable risks, we make several recommendations to each draft, including improvements to categorization of toxicological similarity and evaluation of chemical risk and the inclusion of additional TSCA and non-TSCA chemicals in the phthalates cumulative chemical group. 

Read Draft Proposed Principles of Cumulative Risk Assessment under the Toxic Substances Control Act” Comments. Read “Draft Proposed Approach for Cumulative Risk Assessment of High-Priority Phthalates and a Manufacturer-Requested Phthalate under the Toxic Substances Control Act” Comments.