On November 18th, Global Automakers submitted comments to the Environmental Protection Agency (EPA) on the TSCA Work Plan Initial Assessments for the flame retardant clusters. Topics covered by the comments included:
- The need for predictability for alternative uses
- The need to distinguish between exposure from articles and the chemicals themselves
- The need to exempt replacement parts
- Ongoing uses of the flame retardants included in the Initial Assessments
Details can be found in the comments attached.