EPN Submits Comments on o and p – DCB Draft Risk Evaluations
On October 8, 2026, EPN submitted formal comments on EPA’s draft risk evaluations for ortho-dichlorobenzene (o-DCB) and para-dichlorobenzene (p-DCB) under the Toxic Substances Control Act (TSCA). EPN’s submission highlighted serious procedural concerns regarding how the agency is executing its Existing Chemicals Review Program. While EPA solicited public feedback on the draft risk evaluations, the agency published them before the Science Advisory Committee on Chemicals (SACC) had completed its peer-review report. Although EPA subsequently posted the SACC report on September 14, EPN warns that this recurring pattern of out-of-sync releases deprives the public of sufficient time to thoroughly digest the independent panel’s scientific findings and incorporate them into their comments before the October 9 deadline.
