Comments on Proposed Interim Registration Review Decision for Chlorpyrifos and Revised Draft Human Health Risk Assessment, 85 Fed. Reg. 78,849
On February 5, 2021, the Clinic submitted a comment letter urging the Environmental Protection Agency (EPA) to reverse its proposed registration decision for chlorpyrifos and revise the underlying Human Health Risk Assessment (HHRA). The Clinic’s letter calls into question EPA’s decision to use 10% red blood cell acetyl cholinesterase (AChE) inhibition as the basis for the toxicological point of departure, and argues that the HHRA’s refusal to rely on the findings of a key epidemiological study is irrational and contrary to EPA’s longstanding commitment to rely on the best available science.