Comment submitted by Natural Resources Defense Council (NRDC)
AnonymousOpposeAdvocacy
Summary: The Natural Resources Defense Council and Earthjustice argue that the EPA's use of new approach methods (NAMs) in the draft risk evaluations for HHCB and dichlorobenzenes is unjustified and inconsistent with "best available science." They contend that the EPA is relying on insufficient 5-day transcriptomic studies to dismiss evidence of carcinogenicity and is failing to follow its own guidance regarding uncertainty factors and the inclusion of both male and female test subjects.
The Natural Resources Defense Council and Earthjustice respectfully submit the following comments on EPA's draft risk evaluation for HHCB and draft hazard assessments for o-dichlorobenzene and p-dichlorobenzene.