1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-Hexamethylcyclopenta [g]-2-Benzopyran (HHCB); Phthalic Anhydride; o-Dichlorobenzene (o-DCB) and p-Dichlorobenzene (p-DCB); Science Advisory Committee on Chemicals (SACC) Peer Review; Draft Risk Evaluations; Notice of SACC Meeting; Availability of Draft Documents and Request for Comment

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.

The American Chemistry Council p-DCB Risk Evaluation Consortium, represented by consultants from Integral Consulting and Three Points Ecotox Consulting, submitted comments regarding the draft hazard assessment for p-dichlorobenzene. They generally support the EPA's transcriptomic analysis and mode of action assessment but recommend using alternative studies and methodologies to establish more accurate points of departure for various exposure routes.