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The American Chemistry Council (ACC) today filed comments with the Environmental Protection Agency regarding its updated risk determination for Cyclic Aliphatic Bromide Cluster (HBCD). Of particular concern, for the first time, EPA has taken a “whole chemical approach” to a risk determination—instead of making “condition-of-use-specific” determinations. Also, in a critical change of course, the Agency has chosen to assume that personal protective equipment (PPE), including PPE required by OSHA, is not used in the workplace.
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