NCHR Comments on EPA’s Draft for Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)

 December 27, 2022: NCHR public comments on EPA’s proposed draft supports the need for recordkeeping and reporting as they are vital steps toward managing perfluoroalkyl and polyfluoroalkyl substances (PFAS). However, there are accountability loopholes identified in this proposed draft that could allow manufacturers to take advantage of the system, ie. making it optional to register an unknown chemical with a CASRN or other identifier and not required. It is for reasons like this that we believe the draft does not go far enough.

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NCHR’s Comment on the Draft IRIS Assessment Plan and Protocol for Assessing Cancer Risk from Inhalation Exposure to Cobalt and Cobalt Compounds

NCHR supports the EPA’s decision to assess the risk for cancer from inhalation exposure to cobalt and cobalt compounds. Other health organizations recognize that cobalt is a likely human carcinogen based on animal studies, and it is important for the EPA to investigate if the same link extends to humans as well. An analysis of the evidence is needed to understand the upper-dose limit and how to prevent dangerous exposures to cobalt and cobalt compounds. By providing these results, we hope organizations create guidelines and requirements that the industry must follow to protect worker’s health and well-being of the public.

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NCHR Comments on EPA truck pollution standards

May 16, 2022. NCHR agrees with the Environmental Protection Agency (EPA) that the proposed truck pollution standards, which would reduce emissions of smog- and soot-forming nitrogen oxides, are a crucial step towards EPA’s commitment to climate, clean air and environmental justice. However, in light of the ongoing health and climate crisis, the proposed standards fall short of a zero-emission transportation future, and we urge EPA to further strengthen the proposed standards. This has also long been requested by environmental justice communities across the country, because while truck pollution has been devastating the health of communities across the country, it has a disproportionate impact on communities of color.

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