Comment submitted by American Coatings Association (ACA)

Summary: The American Coatings Association (ACA) opposes the EPA's draft risk evaluation of phthalic anhydride, arguing that the EPA overestimates exposure levels in end-use products by conflating resin manufacturing with downstream paint formulation. The association contends that phthalic anhydride is largely consumed during the resin-making process, leaving only trace amounts in final products, and requests that the EPA use updated Safety Data Sheets (SDS) and more representative scientific studies.