Arlington, VA-ACI submitted comments on the Octamethylcyclotetra- siloxane (D4) TSCA Review and contends that the Environmental Protection Agency’s (EPA) draft risk evaluation of D4 is flawed and inconsistent with Toxic Substances Control Act (TSCA) requirements. The EPA failed to use the industry’s comprehensive draft risk evaluation and did not apply a proper weight-of-evidence approach.
Industry submitted monitoring data and peer-reviewed studies show negligible environmental and health risks at real world exposure levels. Several other nations have found minimal risk and imposed few restrictions.
Banning or limiting D4 in the U.S. would disrupt silicone manufacturing, raise compliance costs, and force reformulation of thousands of products. Consequences include higher consumer prices, inferior product performance, supply chain disruptions, and weakened competitiveness in advanced materials.
ACI urges EPA to reconsider its draft evaluation, fully incorporate SEHSC’s scientific data, and adopt a balanced, evidence-based determination. Unnecessary restrictions would harm consumers, erode U.S. manufacturing leadership, and stifle innovation.
Read ACI’s public comments here.
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The American Consumer Institute is a nonprofit education and research organization.