Comment submitted by Environmental Defense Fund (EDF)

Summary: The Environmental Defense Fund (EDF) argues that the EPA's Draft Risk Evaluation for Phthalic Anhydride significantly underestimates risks to workers, consumers, and fenceline communities. They specifically criticize the EPA's assumptions regarding hydrolysis rates in air, the failure to account for synergistic mixture effects between phthalic anhydride and o-phthalic acid, and the use of insufficiently protective uncertainty factors.