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ACC Comments Draft Revision to TSCA Risk Determination for Colour Index Pigment Violet 29 

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.

American Chemistry Council

The American Chemistry Council’s mission is to advocate for the people, policy, and products of chemistry that make the United States the global leader in innovation and manufacturing. To achieve this, we: Champion science-based policy solutions across all levels of government; Drive continuous performance improvement to protect employees and communities through Responsible Care®; Foster the development of sustainability practices throughout ACC member companies; and Communicate authentically with communities about challenges and solutions for a safer, healthier and more sustainable way of life. Our vision is a world made better by chemistry, where people live happier, healthier, and more prosperous lives, safely and sustainably—for generations to come.

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