Comment submitted by Willert Home Products

Summary: Bergeson & Campbell, P.C. is submitting oral comments on behalf of Willert Home Products, an importer and processor of p-dichlorobenzene (p-DCB). The commenter supports the EPA's use of existing risk assessments and BMD modeling but argues that a specific study (Bernatowicz et al., 1994) is not robust enough to serve as the key study for acute oral toxicity.