Comment submitted by Earthjustice et al.
AnonymousOpposeAdvocacy
Summary: A coalition of environmental and health advocacy organizations opposes the EPA's draft risk evaluation of HHCB, arguing that the agency failed to assess all conditions of use and ignored significant exposure pathways. They contend that the EPA's "tiered approach" is unlawful under TSCA and that the agency failed to incorporate "reasonably available" toxicity studies and aggregate exposure data.
Alaska Community Action on Toxics, Breast Cancer Prevention Partners, Center for Environmental Health, Earthjustice, Natural Resources Defense Council and Weaving Voices for Health & Justice submit the attached comments on EPA's draft risk evaluation draft risk evaluation for 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8- hexamethylcyclopenta [y]-2-benzopyran (“HHCB”).