1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-Hexamethylcyclopenta [g]-2-Benzopyran (HHCB) and Phthalic Anhydride Draft Risk Evaluations Under the Toxic Substances Control Act (TSCA); Notice of Availability and Request for Comment

The American Coatings Association (ACA) opposes the EPA's draft risk evaluation of phthalic anhydride, arguing that the EPA overestimates exposure levels in end-use products by conflating resin manufacturing with downstream paint formulation. The association contends that phthalic anhydride is largely consumed during the resin-making process, leaving only trace amounts in final products, and requests that the EPA use updated Safety Data Sheets (SDS) and more representative scientific studies.

The People’s Republic of China submitted comments regarding the draft risk evaluations for HHCB and Phthalic Anhydride. The government requests that the EPA recognize equivalent overseas safety measures, clarify specific high-risk conditions of use to avoid broad trade restrictions, and provide precise definitions for "spray-type" consumer products.

The Aerospace Industries Association (AIA) provides feedback on the EPA's draft risk evaluation for phthalic anhydride, emphasizing its critical role in aerospace and defense manufacturing. They request clarification on specific conditions of use (COUs) to ensure accurate classification and propose a performance-based approach for personal protective equipment (PPE) rather than prescribing specific glove models.

Beyond Plastics, an organization working to eliminate plastic pollution, urges the EPA to strengthen its draft risk evaluation of phthalic anhydride. They argue that the EPA should better account for fenceline community exposures, aggregate exposures, risks to susceptible populations (such as pregnant individuals), and the chemical's role in the broader toxic plastic supply chain.

The Chemical Company, a chemical distributor, argues that Phthalic Anhydride does not pose a risk to workers or consumers because it is transformed during production and does not remain in the final product. They state they cannot provide specific exposure data as they are not involved in manufacturing or end-use.