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

Integral Consulting Inc., representing Stepan Company, argues that the EPA's draft risk evaluation for phthalic anhydride is overly conservative and based on inaccurate exposure data. They advocate for prioritizing more recent, well-annotated data, revising the dermal sensitization benchmark, and reducing the proposed uncertainty factors to better reflect actual occupational conditions.

LANXESS Corporation argues that because their facility uses highly engineered closed systems, robust administrative controls, and high-tier PPE, further regulations for phthalic anhydride are unnecessary. They request that the EPA recognize these existing safety measures and provide flexibility regarding air monitoring for low vapor pressure chemicals.