Project Overview: For an industry trade group, Cardno ChemRisk critiqued and provided commentary on the draft EPA TSCA risk evaluations for four prioritized chemicals.
Our Approach: For each chemical, we reviewed the occupational exposure assessment methods for all routes of exposure and provided in-depth commentary and alternative strategies (including alternate data sources, analysis methods, and/or exposure assumptions) that EPA could employ to strengthen the exposure assessments. Our comments were submitted to the Science Advisory Committee on Chemicals and to EPA for consideration in revisions to the draft risk evaluations. We also prepared and presented oral comments to the Scientific Advisory Committee for one of the chemicals. We continue to work with the client to provide support in the risk management phase of the TSCA process.
Our Value: In response to our comments, EPA performed additional statistical analyses of occupational exposure data and updated risk evaluation discussions in the final risk evaluation.