The Draft Revised Unreasonable Risk Determination for C.I. Pigment Violet 29 (PV29), published on March 7, 2022, reflects the second time EPA has taken a “whole chemical approach” to a risk determination as opposed to making risk determinations for individual conditions of use (COUs).1 It also reflects the= assumption that personal protective equipment (PPE) is not used in the workplace, and therefore, PPE will not be considered for risk determinations.
EPA has not adequately supported its decisions to implement a whole chemical approach in the PV29 risk evaluation, and to not assume use of PPE in TSCA risk determinations. Moreover, fatal flaws in the final risk evaluation of PV29 resulted in unwarranted determinations of unreasonable risk. ACC’s comments express several key concerns with the risk evaluation and risk determination process that need to be addressed, including the below points.