EPN Comments on PV29 Draft Revision to TSCA Risk Determination

On April 19, 2022, EPN submitted comments on EPA’s draft revision to the risk determination for the chemical Pigment Violet 29 (PV29) issued under the Toxic Substances Control Act (TSCA). In addition to a revised determination that PV29 presents an unreasonable risk of injury to health when evaluated under its conditions of use, EPA also withdrew the assumption that workers always appropriately wear personal protective equipment (PPE). EPN commended the agency for removing PPE as a factor in the unreasonable risk determination process, a point EPN has made repeatedly in previous comments. While supportive of the implementation of EPA’s whole chemical approach, EPN recommended the agency develop general guidance that would articulate the logic to be used when making a whole chemical risk determination, as well as expanding consideration of exposure pathways.

Read the comments.