Comment submitted by Woodruff Science Policy Lab at Stanford University

Summary: Rashmi Joglekar, representing the Woodruff Science Policy Lab at Stanford University, argues that the EPA's draft risk evaluations for HHCB, Phthalic Anhydride, o-DCB, and p-DCB are based on incomplete evidence and scientifically unsupported assumptions. The commenter criticizes the EPA's use of industry-aligned frameworks and New Approach Methodologies (NAMs) to downplay health hazards and calls for a revision of the assessments using gold-standard systematic review methodologies.