Posted on 08/04/2022 in Regulatory 2022
Debate on EPA risk conclusions on HBCD

US EPA’s conclusion on risks of the brominated FR, HBCD, faces questions on “whole-chemical” approach.. The EPA’s final Risk Assessment of hexabromocyclododecane and the cyclic aliphatic bromide cluster (HBCD), December 2021, see pinfa Newsletter n°135, concludes impacts on aquatic plants, fish embryos, aquatic invertebrates, earthworms and priority human health impact on the thyroid hormone. The American Chemical Council has filed comments objecting to the “whole chemical approach” used instead of “condition-of-use-specific” risk determinations. Environmental associations, on the other hand, consider that the “whole chemical” approach respects the wording of the law (TCSA) which refers to “chemical substance”. This “whole chemical” approach is now being applied to revise EPA decisions on a number of chemicals.

“ACC Calls for EPA To Reconsider Its Misguided “Whole Chemical Approach” and Assumptions about PPE”, 4th March 2022

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