Comment submitted by Environmental Defense Fund (EDF)

Summary: Dr. Paige Varner, representing the Environmental Defense Fund, argues that the EPA's draft risk evaluation for phthalic anhydride substantially underestimates risks to the public. She identifies several deficiencies, including the failure to assess ambient air exposure for fenceline communities, the omission of mixture effects with o-phthalic acid, and the use of insufficiently protective uncertainty factors.