Comments Submitted on Draft Scope
April 3, 2025
Beyond Plastics, Earthjustice, Environmental Defense Fund, Natural Resources Defense Council, and Toxic-Free Future submitted comments on the Draft Scope of the Risk Evaluation Under the Toxic Substances Control Act. The comments recommend that the agency take a broad approach on the Scope for evaluating the risk of vinyl chloride under TSCA. EPA should evaluate the cumulative risks of vinyl chloride exposure with other chemicals; should deem unplanned incidents, including during transportation, as "reasonably foreseen" due to their frequency; and should assess all exposure pathways including soil, surface and groundwater, landfills, and drinking water.
