Comment submitted by ToxStrategies, LLC

Summary: Chad Thompson, a Senior Managing Scientist at ToxStrategies (a BlueRidge Life Sciences Company), provides technical comments on the EPA's draft risk evaluation of Phthalic Anhydride. He supports the EPA's selection of specific uncertainty factors (UFH-TK of 1 and UFL of 3), arguing that the data and modeling support a total UF of 10.