Comment submitted by ToxStrategies, LLC

Summary: Julie Panko, representing ToxStrategies LLC (funded by the American Chemistry Council’s Phthalic Anhydride TSCA Risk Evaluation Consortium), argues that the EPA's risk evaluation of Phthalic Anhydride overestimates worker exposure. She recommends that the EPA use more granular job titles to avoid misclassification, use task-level data rather than extrapolated 8-hour TWAs, and account for standard operating procedures regarding dermal PPE.