NRDC Comments on EPA TSCA Systematic Review

Comments
August 16, 2018

NRDC comments detail the serious flaws and industry-bias in the systematic review method used by the EPA to evaluate chemical risks under the Toxic Substances Control Act (TSCA). The TSCA Systematic Review document is less about evaluating the quality of evidence, and more about eliminating it altogether. The document is incomplete, inconsistent with the state of the science, and too flawed to be used. Accordingly, use of the document violates TSCA and is otherwise arbitrary and capricious.