Global Automakers provided comments to the California Department of Toxic Substance Control on its draft 2018-2020 Work Plan, under the Safer Consumer Product program, raising questions about the inclusion of lead acid batteries. While required by statute to include lead acid batteries in the Work Plan, Global Automakers believes that without the statute, lead-acid batteries would not have been included. Lead-acid batteries have a nearly 100 percent recycling rate and almost no risk of exposure to consumers. Information to support this conclusion has been provided by Global Automakers and other stakeholders throughout the extensive stakeholder process to date. Global Automakers therefore requests in these comments that DTSC conclude its evaluation of LABs and determine that they should not be listed as priority products.