Comment from O'Donnell, Rebecca; American Chemistry Council (ACC)

Summary: The American Chemistry Council (ACC) supports the U.S. leadership in the UNSCEGHS and advocates for a science-based, hazard-communication-focused approach to the Globally Harmonized System (GHS). They provide specific technical recommendations regarding endocrine disruptors, persistence and mobility, terrestrial toxicity, and germ cell mutagenicity criteria to ensure they are based on robust scientific evidence rather than political demand or environmental fate properties.