Industry Attorneys See Unanswered Questions In EDF Cumulative Risk Model

September 29, 2022
Industry attorneys say the Environmental Defense Fund’s (EDF) novel framework for EPA to analyze cumulative risks under TSCA leaves open major questions on how the agency would approach such assessments, including many technical issues as well as the likely resource demands of such efforts, even as they applauded the group’s work. “The issue of how to perform a scientifically robust cumulative risk assessment is highly complex and far more complex than EDF makes out,” Herb Estreicher, a partner with the...

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