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SEPA

EPA Document# EPA-740-P-23-001
February 2023

United States	Office of Chemical Safety and

Environmental Protection Agency	Pollution Prevention

Draft Proposed Principles of Cumulative Risk Assessment
under the Toxic Substances Control Act

February 2023


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1	TABLE OF CONTENTS	

2	ACKNOWLEDGEMENTS	3

3	ABBREVIATIONS AND ACRONYMS	4

4	1 INTRODUCTION	5

5	2 SCOPE	6

6	3 PROPOSED PRINCIPLES OF CRA UNDER TSCA	7

7	3.1 Populations for Consideration	7

8	3.2 Stressors for Consideration	8

9	3.3 Sources, Pathways, and Routes of Exposure Considered	8

10	3.4 Chemical Grouping Considerations	9

11	3.4.1 Toxicologic Similarity	9

12	3,4.2 Co-exposure Considerations	10

13	3.5 Additivity Considerations for Evaluating Cumulative Chemical Groups	13

14	3.6 Addressing Data Gaps	14

15	3.7 Cumulative Risk Assessment Refinement Considerations	14

16	4 CHARACTERIZATION OF CUMULATIVE RISK UNDER TSCA	15

17	5 SUMMARY	16

18	6 REFERENCES	17

19	Appendix A GLOSSARY OF KEY TERMS	19

20

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ACKNOWLEDGEMENTS	

This report was developed by the United States Environmental Protection Agency (U.S. EPA), Office of
Chemical Safety and Pollution Prevention (OCSPP), Office of Pollution Prevention and Toxics (OPPT).

Acknowledgements

The OPPT Assessment Team gratefully acknowledges participation or input from intra-agency
reviewers that included multiple offices within EPA. EPA also acknowledges the contributions of
technical experts from EPA's Office of Research and Development.

Docket

Supporting information can be found in public docket, Docket ID: EPA-HQ-OPPT-2022-0918
(https ://www.regulations. gov/document/EP A-HQ-OPPT-2022-0918-0001)

Disclaimer

Reference herein to any specific commercial products, process or service by trade name, trademark,
manufacturer, or otherwise does not constitute or imply its endorsement, recommendation, or favoring
by the United States Government.

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ABBREVIATIONS AND ACRONYMS

CDR

Chemical Data Reporting

COU

Conditions of Use

CRA

Cumulative risk assessment

EPA

U.S. Environmental Protection Agency

FQPA

Food Quality Protection Act

HI

Hazard index

IPCS

International Programme on Chemical Safety

MIE

Molecular initiating event

MOA

Mode of action

MOE

Margin of exposure

NEI

National Emissions Inventory

NRC

National Research Council (now the National Academies of Sciences, Engineering, and



Medicine)

OCSPP

Office of Chemical Safety and Pollution Prevention

OECD

Organisation for Economic Co-operation and Development

OLEM

Office of Land and Emergency Management

ONU

Occupational non-user

OPP

Office of Pesticide Programs

OPPT

Office of Pollution Prevention and Toxics

ORD

Office of Research and Development

PESS

Potentially exposed or susceptible subpopulation(s)

(Q)SAR

(Quantitative) structure-activity relationship

RAF

Risk Assessment Forum

RPF

Relative potency factor

SACC

Science Advisory Committee on Chemicals

TRI

Toxics Release Inventory

TSCA

Toxic Substances Control Act

WHO

World Health Organization

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1 INTRODUCTION	

The Frank R. Lautenberg Chemical Safety for the 21st Century Act amended the Toxic Substances
Control Act (TSCA), the Nation's primary chemicals management law, in June 2016. Through the
amended statute, the U.S. Environmental Protection Agency (EPA or the Agency) is required, under
TSCA section 6(b), to conduct risk evaluations to determine whether a chemical substance presents an
unreasonable risk of injury to health or the environment, without consideration of costs or other non-risk
factors, including an unreasonable risk to potentially exposed or susceptible subpopulation(s) (PESS)
identified by EPA as relevant to the risk evaluation, under the conditions of use (COU). TSCA section
6(b)(4)(A) requires EPA to consider PESS, which are subpopulations "who, due to either greater
susceptibility or greater exposure, may be at greater risk than the general population of adverse health
effects from exposure to a chemical substance or mixture, such as infants, children, pregnant women,
workers, or the elderly" [15 U.S.C. § 2602(12)]. Several reports from the National Research Council
(NRC)—including the 1994 report Science and Judgment in Risk Assessment, the 2008 report Phthalates
and Cumulative Risk Assessment: The Tasks Ahead, and the 2009 report Science and Decisions:
Advancing Risk Assessment—have highlighted the importance of understanding the combined risk from
multiple environmental stressors (NRC. 2009. 2008. 1994). These reports, as well as legislation such as
the Food Quality Protection Act of 1996 (FQPA), have driven, in part, EPA's evolving work on
cumulative risk assessment (CRA).

TSCA does not explicitly require EPA to conduct CRAs. However, TSCA does require that EPA, when
conducting TSCA risk evaluations in 3 to 3.5 years [15 U.S.C. § 2605(b)(4)(G)], consider the reasonably
available information, consistent with the best available science, and make decisions based on the
weight of the scientific evidence [15 U.S.C. § 2625(h), (i), (k)]. EPA recognizes that for some chemical
substances undergoing risk evaluation, the best available science may indicate that the development of a
CRA is appropriate to ensure that any risks to human health and the environment are adequately
characterized. TSCA also gives the Agency the authority to consider the combined risk from multiple
chemical substances when there is an interrelated group of chemicals or mixtures [15 U.S.C. § 2625(c)],
Under TSCA section 26(c), EPA may take "any action authorized" under any provision of TSCA, in
accordance with that provision with respect to a category of chemical substances or mixtures of
chemical substances. Because individuals are co-exposed to many chemicals in their daily lives, some of
which may have the same health effects, EPA believes that in some cases the best approach to assess
risk to human health may be to look at the combined risk to health from exposure to multiple chemicals.

EPA plans to solicit comments on this draft document from the Science Advisory Committee on
Chemicals (SACC) and the public, which may be used in the future as part of the development of a more
detailed TSCA CRA Framework and in support of future CRAs.

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2 SCOPE	

EPA has developed this draft principles document providing an overview of TSCA and defining CRA
within the requirements of TSCA. This draft document is not a framework nor a guidance document on
the process for conducting CRAs; rather, it focuses on principles of CRA for chemical substances. There
are multiple definitions of the term "cumulative risk assessment." This draft principles document
primarily relies on the definition in EPA's Framework for Cumulative Risk Assessment that defines
CRA as "an analysis, characterization, and possible quantification of the combined risks to health and/or
the environment from multiple agents and/or stressors" (U.S. EPA 2003). This could include evaluation
of multiple chemical substances that jointly exert a common toxic effect. Exposures to these chemicals
could result from multiple exposure pathways and through multiple routes of exposure.

Further, this draft CRA principles document does not address cumulative impacts, which refer to the
total burden—positive, neutral, or negative—from chemical and non-chemical stressors and their
interactions that affect the health, well-being, and quality of life of an individual, community, or
population at a given point in time or over a period of time (U.S. EPA 2022). Cumulative impacts,
which may or may not include toxicologically defined risk, would be considered in other types of
assessments such as a cumulative impact assessment. EPA's Office of Research and Development
(ORD) is actively working to strengthen the scientific underpinning for assessing cumulative impacts.
EPA's Office of Pollution Prevention and Toxics (OPPT) may consider cumulative impacts in the future
and as appropriate data, methods, and guidance are available.

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3 PROPOSED PRINCIPLES OF CRA UNDER TSCA

In the development of this draft principles document, EPA has relied substantially on existing CRA-
related work by EPA's Risk Assessment Forum (RAF), EPA's Office of Pesticide Programs (OPP), the
Organisation for Economic Co-operation and Development (OECD), the European Commission, and the
World Health Organization (WHO) and International Programme on Chemical Safety (IPCS), including

•	Guidelines for the Health Risk Assessment of Chemical Mixtures (U.S. EPA. 1986)

•	Guidance for Identifying Pesticide Chemicals and Other Substances That Have a Common
Mechanism of Toxicity (U.S. EPA. 1999)

•	Supplementary Guidance for Conducting Health Risk Assessment of Chemical Mixtures (U.S.
EPA 2000)

•	General Principles for Performing Aggregate Exposure and Risk Assessments (U.S. EPA. 2001)

•	Guidance on Cumulative Risk Assessment of Pesticide Chemicals that Have a Common
Mechanism of Toxicity (U.S. EPA. 2002a)

•	Framework for Cumulative Risk Assessment (U.S. EPA. 2003)

•	Concepts, Methods and Data Sources for Cumulative Health Risk Assessment of Multiple
Chemicals, Exposures, and Effects: A Resource Document (U.S. EPA. 2007)

•	State of the Art Report on Mixture Toxicity (European Commission. 2009)

•	Risk Assessment of Combined Exposure to Multiple Chemicals: A WHO IPCS Framework (Meek

etal..20in

•	Pesticide Cumulative Risk Assessment: Framework for Screening Analysis Purpose (U.S. EPA.
2016)

•	Considerations for Assessing the Risks of Combined Exposure to Multiple Chemicals (OECD.
2018)

•	Phthalates and Cumulative Risk Assessment: The Tasks Ahead (NRC. 2008)

These documents provide the scientific foundation for the proposed TSCA CRA principles described in
Sections 3.1 to 3.7.

3.1 Populations for Consideration	

As required under section 6(b)(4) of TSCA, EPA issued a final rule, Procedures for Chemical Risk
Evaluation Under the Amended Toxic Substances Control Act (82 FR 33726) (hereinafter "Risk
Evaluation Rule"), in July 2017, which provides the procedural requirements for EPA's risk evaluations,
including for chemicals designated as High-Priority Substances and chemical substances subject to a
Manufacturer-Requested Risk Evaluation. Pursuant to TSCA section 6(b) and the Risk Evaluation Rule,
risk evaluations must include both hazard and exposure assessments for the chemical substance in order
to characterize any risk that the substance may pose under its COUs to ecological and human
populations. At this time, EPA proposes to focus its CRA efforts on human health, not on ecological
taxa. This is because established Agency cumulative risk guidance documents are available to support
human health, but not yet ecological CRA. The Agency may, in the future, develop an approach for
conducting CRA under TSCA for ecological taxa.

Under TSCA, the key human populations considered include the general population and PESS such as
workers and occupational non-users (ONUs), consumers and consumer bystanders, fenceline
communities, and tribal populations. TSCA section 6(b)(4)(A) requires EPA to determine whether a
chemical substance presents an unreasonable risk of injury to health or the environment—without
consideration of costs or other non-risk factors, including to PESS [15 U.S.C. § 2605(b)(4)(A)], As
noted previously, PESS are subpopulations "who, due to either greater susceptibility or greater exposure,
may be at greater risk than the general population of adverse health effects from exposure to a chemical

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substance or mixture, such as infants, children, pregnant women, workers, or the elderly" [15 U.S.C. §
2602(12)]. TSCA does not statutorily define what constitutes "greater susceptibility" or "greater
exposure," thereby providing flexibility to EPA to consider both chemical and non-chemical stressors
when identifying PESS. As OPPT continues to develop its approaches for CRA, OPPT will take into
consideration PESS in hazard, exposure, and risk methods and results.

3.2	Stressors for Consideration	

Under EPA's RAF description of cumulative risk (U.S. EPA 2003). the term "stressors" refers to both
chemical and non-chemical stressors. Non-chemical stressors may include radiological, biological, and
other physical stressors; lifestyle conditions; and socioeconomic stressors. Non-chemical stressors may
directly or indirectly affect health adversely, increase vulnerability to chemical stressors, or have
exposure-response modifying effects on other chemical stressors (U.S. EPA 2022. 2003). Few methods
have been developed that allow for a quantitative analysis of cumulative risk from combined exposure to
chemical and non-chemical stressors. However, EPA ORD is actively working to strengthen the
scientific underpinning for assessing cumulative impacts, including impacts from non-chemical stressors
within ORD's FY23-26 Strategic Research Action Plans (U.S. EPA. 2022). Until Agency-wide guidance
and established methodologies have been developed, EPA does not expect to quantitatively evaluate
non-chemical stressors when conducting CRAs under TSCA. In contrast, Agency-wide guidance and
methodologies for quantitatively evaluating cumulative risk from combined exposure to multiple
chemical substances and/or mixtures are available (U.S. EPA. 2000. 1986). Therefore, at this time for
purposes of TSCA risk evaluations, EPA is proposing to focus its quantitative CRA efforts on the
evaluation of chemical substances. However, if EPA identifies potential non-chemical stressors that may
be reasonably anticipated to impact cumulative risk estimates from chemical substance exposure, then
EPA may include a qualitative discussion of the non-chemical stressors and their potential impact on a
case-by-case basis until such time that peer-reviewed, Agency-wide guidance for quantitative evaluation
of non-chemical stressors is available.

3.3	Sources, Pathways, and Routes of Exposure Considered	

If EPA determines in a TSCA section 6(b) risk evaluation that the manufacture, processing, distribution
in commerce, use, or disposal of a "chemical substance," or that any combination of such activities
presents an unreasonable risk of injury to health or the environment, then TSCA section 6(a) requires
EPA to regulate the manufacture, processing, distribution in commerce, commercial use, or disposal of
the "chemical substance" to the extent necessary so that the "chemical substance" or mixture no longer
presents such risk [15 U.S.C. 2605(a)],

TSCA section 6(b)(4)(D) requires EPA to identify the hazards, exposures, conditions of use, and the
PESS the Administrator expects to consider in a risk evaluation. TSCA section 3(2) excludes from the
definition of "chemical substance" "any food, food additive, drug, cosmetic, or device (as such terms are
defined in Section 201 of the Federal Food, Drug, and Cosmetic Act [21 U.S.C. 321]) when
manufactured, processed, or distributed in commerce for use as a food, food additive, drug, cosmetic, or
device" as well as "any pesticide (as defined in the Federal Insecticide, Fungicide, and Rodenticide Act
[7 U.S.C. 136 et seq.]) when manufactured, processed, or distributed in commerce for use as a
pesticide." EPA may not in a risk management rule under section 6(a) directly regulate non-TSCA uses;
however, incidental effects of 6(a) regulation on non-TSCA uses are not prohibited by TSCA's chemical
substance definition. Additionally, as described in EPA's Risk Evaluation Rule (see Procedures for
Chemical Risk Evaluation Under the Amended TSCA, 33726 Fed. Reg. 33735 (July 20, 2017), "[t]he
potential risks of non-TSCA uses may help inform the Agency's risk determination for the exposures
from uses that are covered under TSCA (e.g., as background exposures that would be accounted for,
should EPA decide to evaluate aggregate exposures)" 82 FR at 33735. For example, EPA may take into

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account exposure to multiple chemical substances resulting from non-TSCA uses and/or naturally
occurring sources, should the Agency decide to conduct a CRA.

Relevant pathways and routes of exposure to a person from various sources will be considered for a
CRA conducted under TSCA. Potentially relevant routes of exposure include inhalation, oral, and
dermal routes. Possible pathways of exposure to a chemical substance may include, but are not limited
to, ingestion of contaminated groundwater, inhalation of volatile compounds emitted in an indoor
environment, or dermal exposure to products during use. The determination of which exposure routes
and pathways to include in a CRA requires consideration of the toxicological endpoint(s) selected on the
basis of toxicologic similarity (discussed further in Section 3.4.1) and the likelihood of single or
multiple routes or pathways to result in co-exposure within a relevant timeframe (discussed further in
Section 3.4.2). For example, if a toxicologic effect is only observed following exposure via certain
routes, then it may be appropriate to evaluate only those routes of exposure as part of the CRA.

Similarly, unless various pathways of exposure result in co-exposures within a relevant timeframe, they
may not be considered as part of a CRA.

3.4 Chemical Grouping Considerations	

Under TSCA, the term "category of chemical substances" is broadly defined as "a group of chemical
substances the members of which are similar in molecular structure, in physical, chemical, or biological
properties, in use, or in mode of entrance into the human body or into the environment, or the members
of which are in some other way suitable for classification" [15 U.S.C. § 2625(c)(2)(A)], This broad
definition provides EPA with the flexibility to group chemical substances for inclusion in a CRA based
on defined criteria hereinafter referred to as a "cumulative chemical group."

Available EPA (2016. 2003. 2002a. 2000. 1986). OECD (2018). and World Health Organization/
International Programme on Chemical Safety (WHO/IPCS) (Meek et al.. 2011) guidance outlines two
principal considerations for grouping chemicals for inclusion in a CRA, (1) toxicologic similarity, and
(2) evidence of co-exposure over a relevant timeframe. Consistent with available guidance, toxicological
similarity and evidence of co-exposure will be the principal considerations when determining chemical
groupings for CRA under TSCA. Consideration for determining toxicologic similarity and co-exposure
over a relevant timeframe under TSCA are discussed in Sections 3.4.1 and 3.4.2, respectively. The
establishment of a cumulative chemical group for purposes of CRA will be developed using a narrative
that clearly characterizes the strengths and uncertainties of the evidence of toxicological similarity as
well as the potential co-exposure for each chemical substance in the cumulative chemical group
considered.

3.4.1 Toxicologic Similarity

As described in EPA's Supplementary Guidance for Conducting Health Risk Assessment of Chemical
Mixtures (mixtures guidance) (U.S. EPA 2000). evidence for toxicological similarity exists along a
continuum and includes, but may not be limited to (from most to least informative/restrictive with regard
to data and knowledge requirements) the following:

•	identical toxicodynamics (i.e., same molecular initiating event [MIE], downstream key events,
and apical outcome; an example of this is a group of chemical substances that have a common
toxic metabolite);

•	similar toxicodynamics (e.g., different MIE, convergent toxicodynamic pathways leading to a
common downstream effect, and same apical outcome);

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•	shared syndrome (e.g., phthalate syndrome (NRC. 20081 T (tremor)-syndrome or CS
(choreoathetosis and salivation)-syndrome elicited by Type I and II pyrethroids, respectively
(U.S. EPA. 2011));

•	shared apical outcome (MIE and other key events unknown);

•	effect on the same target organ;

•	structural similarity; and

•	similarly shaped dose-response curves in comparable toxicity studies.

Empirical evidence from mixture studies may also provide support for establishing cumulative chemical
groups for CRA. Generally, EPA is unlikely to conduct CRAs under TSCA when the reasonably
available information is limited to an effect on the same target organ as this approach may introduce too
much uncertainty to risk estimates.

A variety of toxicodynamic information can be used to inform the degree of toxicologic similarity of a
cumulative chemical group. The quality, quantity, and relevance of this information must be discussed
as part of the weight of evidence narrative. EPA's mixtures guidance (U.S. EPA 2000) and other
international guidance (OECD. 2018; Meek et al.. 2011) describe examples of data sources that may
provide evidence of toxicological similarity, including:

•	In vivo studies: Evidence of toxicologic similarity may come from both animal studies
(guideline and non-guideline) and human studies. Animal studies may provide evidence of the
same target organ, shared apical outcome or syndrome, similar toxicokinetics (including potency
of metabolites and metabolites common to multiple chemicals), and/or the same mode of action
(MOA). Analyses of data from in vivo (as well as ex vivo and in vitro) studies may also provide
evidence of similarly shaped dose-response curves (e.g., linear or S-shaped), which can provide
support for proportional toxicodynamics. Human studies, including controlled human exposure
and epidemiologic studies, may provide additional evidence of a common target organ, shared
apical effect or syndrome, as well as provide evidence of species concordance and human
relevance of effects observed in animal models.

•	Ex vivo studies: Organ and tissue studies may provide information about shared toxicodynamic
events and pathways or evidence of the effect on the same target organ. In some cases, these
studies may also provide information about shared toxicokinetics (absorption, metabolism, etc.),
shared metabolites, or apical endpoint (e.g., eye irritation, skin sensitization).

•	In vitro studies: Cell-based bioassays and other in vitro high-throughput screening techniques
(e.g., ToxCast and Tox21 testing programs, three-dimensional tissue models, mechanistic or
metabolic assays, etc.) may inform assumptions about toxicologic similarity by providing
information on mechanism and/or MO A, as well as target organ effect data. In addition, in vitro
(as well as in vivo) mixture studies can provide empirical evidence for toxicologic similarity
when observed dose-response data are consistent with dose additive predictions.

•	In silico studies: In silico tools may provide predictive evidence that supports toxicologic
similarity. For example, structure-activity relationship and quantitative structure-activity
relationship (i.e., [Q]SAR) modeling can provide predictive hazard information on the target
organ, apical outcome, or MOA. Similarly, molecular docking approaches can be used to predict
interactions between a chemical and protein, which may inform a chemical's MOA. These tools
may also help characterize structural similarity.

3.4,2 Co-exposure Considerations

In addition to toxicological similarity, inclusion and grouping of two or more chemical substances into a
CRA requires consideration of whether exposure to multiple chemical substances occur at
toxicologically significant concentrations and over relevant and/or overlapping timeframes (e.g., during

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a critical window of development). When determining relevant timeframes of exposure the duration or
frequency that is relevant to effects of concern should be taken into account. Relevant timeframes may
include, but may not be limited to, exposure to multiple chemicals at the same time, exposure to
persistent chemicals at different times that may bioaccumulate in the body or have persistent effects
from exposure to multiple chemicals at different times. Relevant timeframes of exposure can vary by
factors including, but not limited to, chemicals, lifestages, or effects.

Characterizing co-exposure requires consideration of the source of chemical exposure, populations
impacted by exposure, and the possible varying routes and pathways of exposure. Additionally, the
magnitude, frequency, and duration of exposure to multiple chemical substances influence the potential
for co-exposure to occur within a given period of time (e.g., 24 hours, 1 year, or a lifetime); where the
magnitude of exposure is the level of exposure dictated by the physical and chemical properties of the
chemical substance and exposure scenario, frequency is the number of exposure events over a given
time, and duration is the length of exposure time per event (OECD. 2018; U.S. EPA 2001).

Because chemical substances are assessed for risk under the COUs, the magnitude of exposure is
calculated through individual exposure scenarios that consider the source, pathway, route, media,
frequency, and duration of an exposure and should be considered against the concentration of
toxicological significance. The frequency of exposure can be given as the predicted number of days in
which an exposure occurs in a year or the number of exposure events in a given timeframe such as per
day, month, or year. Examples of high frequency exposure events could be daily ingestion of drinking
water whereas infrequent exposure events may be a consumer painting their home. The duration of
exposure is the length of time in which a person is exposed to the chemical substance of interest and can
vary in length, from short-term (e.g., use of bathroom cleaner) to long-term (e.g., continuous emissions
from home flooring). Relevant exposure patterns incorporating frequency and duration should be
matched with relevant adverse effects when conducting a CRA (U.S. EPA 2001). For example, if an
adverse effect is observed in animals after a single, acute exposure, then it would be most appropriate to
estimate cumulative risk based on acute or single-day exposure estimates. Alternatively, if an adverse
effect is observed after sub-chronic or chronic exposure, then cumulative risk should be estimated based
on corresponding relevant timeframes of exposure duration. An exception to this may be for certain
developmental effects that occur after an acute or short-term exposure takes place during a window of
susceptibility during pregnancy. In such cases, the acute or short-term developmental exposure may be
considered more relevant than a lifetime of exposure and may be considered as part of a chronic
assessment (U.S. EPA 2002b. 1991).

Taken together, frequency and duration impact the potential for co-exposure to multiple chemical
substances. Specifically, continuous long-term exposure to a chemical substance may increase the
likelihood of co-exposure to another chemical substance simultaneously. In contrast, an infrequent short-
term exposure to a chemical substance may not result in a co-exposure to another chemical substance
where the relevant timeframe of exposure may be defined as the time in which exposure to multiple
chemical substances is occurring simultaneously (OECD. 2018; U.S. EPA 2001). Some examples of co-
exposures that may occur simultaneously could include use of a product containing multiple chemical
substances, simultaneous use of multiple products containing different chemical substances, or
inhalation of ambient air containing multiple chemical substances. Exposures to multiple chemical
substances can occur at different times, and the timeframe in which all exposures have occurred can still
be considered a relevant timeframe of co-exposure depending on factors such as biological persistence
of the relevant chemical substances in an organism and the relevant toxicity endpoint of interest (OECD.
2018).

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For example, physical and chemical properties of a chemical substance can impact the biological
persistence of the chemical substance and, therefore, the relevant timeframe of exposure. Even if
exposures to multiple chemical substances do not occur simultaneously, biologically-persistent chemical
substances may remain in the body during exposure to another chemical substance leading to co-
exposure of both chemical substances. Short, intermittent exposures are less likely to result in co-
exposure over a defined timeframe, unless there is evidence of persistence in the body. Additionally, co-
occurrence may not occur for certain chemical substances that are rapidly eliminated from the body—
even with frequent repeated exposure (OECD. 2018; U.S. EPA 2001). However, it may still be
appropriate to consider these chemical substances for inclusion in a CRA if frequent, albeit non-
overlapping exposure, contributes to a subchronic or chronic health effect.

Some data sources that can provide evidence of co-exposures within relevant timeframes to individuals
and populations considered under TSCA include the following:

•	Biomonitoring data: Biomonitoring can be used to both identify individuals and populations
exposed to chemical substances and quantify internal doses of chemical substances.
Biomonitoring data sets can also indicate the presence of multiple chemical substances within
persons of interest (e.g., pregnant women) at the time of sampling and serve as evidence of co-
exposure to multiple chemical substances of interest. However, there are limitations with using
biomonitoring data in a CRA. Quantifying an intake dose from biomonitoring data can be
complicated and requires many assumptions and complex modeling. Although biomonitoring
data may provide evidence that co-exposure is occurring within a relevant timeframe leading to
the presence of multiple chemical substances in the human body, it cannot be used to isolate the
sources, routes, or timeframes of each chemical exposure. Additionally, robust biomonitoring
data may not be widely available for all chemical substances undergoing TSCA risk evaluation.

•	Product formulation data: Co-exposure to multiple chemical substances can occur through
exposures from the presence of multiple chemical substances in a single product (e.g., plastic
products containing multiple phthalates). The presence of multiple chemical substances in a
single product can be determined through process information or production formulation data
provided by the manufacturer of a product or through a safety data sheet. Supporting data on
multiple chemical substances in products or articles may also come from completed chemical
risk assessments, including Agency for Toxic Substances and Disease Registry's Toxicological
Profiles, which often present the prevalence of chemical substances in certain products available
on the U.S. market and relevant usage patterns.

•	Survey of consumer behavior demonstrating co-use: Co-exposures to two or more chemical
substances from multiple COUs result from what is commonly referred to as the co-occurrence
of use (or co-use) and/or co-location of exposure sources. In other words, a determination of co-
exposures is dependent on evidence of co-use and/or co-location. In the context of TSCA, co-
uses typically refer to scenarios from which an individual (e.g., consumer) may be exposed to
two or more COUs such as when a spray and powdered cleaner are used concurrently to clean a
bathtub. For consumer co-exposures, which are primarily dependent on co-use data that are rare
in the literature, studies that report continuous emissions of chemicals even when products are
not in use (e.g., formaldehyde emission from unlit candles, flame retardants that are released
from upholstery via dust over time) can be used to determine which products consumers and
bystanders may be co-exposed to via specific rooms or space of use and periods of time.

•	Workplace monitoring: In industrial and commercial settings, multiple chemical substances
may be manufactured, processed, or used at the same site or location leading to co-exposures of
individuals to various chemical substances. It is important to consider all chemical substances
used for that industry sector or site, their potential hazard, associated worker activities, and

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exposure durations. When available, monitoring studies may provide evidence of exposure to
multiple chemical substances via the workplace environment. Additionally, other site-specific
information may provide evidence of the exposure potential for multiple chemical substances
such as reviewing all the chemical substances reported to EPA programs (e.g., Chemical Data
Reporting [CDR], Toxics Release Inventory [TRI], National Emissions Inventory [NEI]) for a
single site. For occupational co-exposures, information on a facility's chemical formulation,
manufacturing, processing, and uses may be qualitatively considered to determine the potential
of workers and ONUs to be co-exposed to multiple chemicals and through multiple COUs within
an occupational exposure scenario.

•	Facility releases: Emission of multiple chemical substances from a single facility or multiple
facilities within a certain geographical proximity can lead to co-exposures to humans. Similar to
the assessment of exposure in the workplace, site-specific information reported to EPA programs
(e.g., CDR, TRI, NEI) may be used to assess potential releases and resulting co-exposures near
facilities. Unfortunately, location information about environmental releases is typically not
available for every chemical substance.

•	Environmental monitoring: Chemicals present in the environment rarely exist in isolation.
When reasonably available, environmental monitoring data such as measurements of chemical
concentrations in ambient air, indoor air and dust, surface water, drinking water, and soils can
provide evidence of the presence of multiple chemical substances in various environmental
media.

3.5 Additivity Considerations for Evaluating Cumulative Chemical

Groups	

EPA mixtures guidance documents (U.S. EPA 2000. 1986) describe several additivity approaches to
evaluate multiple chemical substances for cumulative risk, including dose addition, response addition,
and integrated addition, as well as approaches to account for toxicologic interactions. EPA's default
assumption when evaluating toxicologically similar chemical substances for cumulative risk is dose
addition (U.S. EPA 2000. 1986). Similarly, the WHO/IPCS and European Commission also recommend
the use of dose addition as the default assumption for estimating risk from exposure to multiple chemical
substances (Meek et al.. 2011; European Commission. 2009). This default assumption is based on
previous analyses of empirical data demonstrating that dose addition is broadly applicable and is a more
conservative, health protective approach than response addition.

EPA's mixtures guidance documents also note that dose addition "provides a simple mathematical
approach that attempts to estimate the outcomes of complex interactions among biological systems and
combinations of chemicals from exposures in the environment" (U.S. EPA. 2000. 1986). The chemical
substances in a mixture that are toxicologically similar are assumed to act as dilutions of one another.
On the basis of dose addition, the response elicited by the mixture can be estimated by scaling
component doses for differences in potency and summing the scaled doses; these scaled doses can be
compared to a dose-response function to estimate risk or a health risk value.

The Agency has used response addition when a group of chemical substances are toxicologically
dissimilar and cause a common adverse health effect through different MO As. For example, EPA's
Office of Land and Emergency Management (OLEM) regularly screens for total cancer risk at
Superfund sites by summing chemical-specific cancer risks under an assumption of response addition
(U.S. EPA. 1989). However, other approaches (e.g., dose addition or integrated addition) may be used to
estimate total cancer risk when in accordance with the best available science and supported by the
weight of scientific evidence.

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Neither TSCA nor EPA's Risk Evaluation Rule mandate the use of a specific additivity model or risk
characterization approach to estimate cumulative hazard or risk (see p. 33,743 of 40 CFR 702).

Consistent with Agency mixtures guidance documents (U.S. EPA 2000. 1986). EPA plans to rely upon
a default assumption of dose addition when conducting CRAs for cumulative chemical groups under
TSCA, unless empirical evidence supports application of another approach (e.g., response addition or
integrated addition, as described in (U.S. EPA. 2000)). Deciding, based on their toxicological similarity,
which chemical substances to include in a cumulative chemical group that subsequently would be
evaluated using dose additive models is an important element of a CRA. When available, various lines
of evidence (see Section 3.4.1) can be used to evaluate the toxicological similarity and membership of a
chemical substance in a cumulative chemical group.

3.6	Addressing Data Gaps	

Section 4 of TSCA gives EPA the authority to issue test rules or orders, as appropriate, that require
manufacturers (including importers) and processors to develop and submit information on chemical
substances and mixtures to EPA [15 U.S.C. § 2603], TSCA section 4(b) requires test rules and orders to
include protocols and methodologies for the development of information for the identified chemical
substance(s) or mixture(s); section 4(b)(2)(A) provides that the health and environmental effects for
which such protocols and methodologies may be prescribed include "cumulative or synergistic effects."
EPA may use this authority to require the development of data to inform the toxicological similarity of a
group of chemical substances undergoing risk evaluation in a CRA. Additionally, the Agency may use
its test order authority to obtain further information on product formulation, emissions testing, and
manufacturing process information to support evidence for co-exposure.

3.7	Cumulative Risk Assessment Refinement Considerations	

Not all CRAs need to be of the same depth or scope (U.S. EPA. 2016; Meek et al.. 2011; U.S. EPA.
2002a). Tiered frameworks for evaluating risk from combined exposure to multiple chemicals have been
developed by OPP (U.S. EPA. 2016) and the WHO/IPCS (Meek et al.. 2011). The objective of those
frameworks is to help assessors develop "fit for purpose" cumulative assessments. They employ
hierarchical approaches in which tiered exposure and hazard assessment are conducted. With each tier,
exposure and hazard assessments become more refined (i.e., less conservative and less uncertain).
Because refinements to exposure and hazard assessments are resource intensive and may require large
amounts of exposure and toxicology data, refinements are typically made when lower tier cumulative
assessments that rely on highly conservative assumptions do not demonstrate an adequate margin of
exposure (MOE). When conservative lower tier assessments indicate an adequate MOE, then a resource
intensive, highly refined CRA may not be warranted. The availability of data for evidence of
toxicological similarity and co-exposure will dictate the level of refinement of cumulative hazard and
exposure assessments, and assessments may still be possible with limited data. For example, the
WHO/IPCS framework (Meek et al.. 2011) outlines various tiers of assessments based on data
availability ranging from a Tier 0 exposure assessment using semiquantitative estimates based on
limited data and simple assumptions, to Tier 3 exposure assessments that are probabilistic in nature and
incorporate representative exposure data for relevant scenarios and populations. Similarly, Tier 0 hazard
assessments may group chemical substances based on a conservative assumption of dose addition with
limited evidence of toxicological similarity (e.g., predictive hazard tools might be used to group
chemical substances based on similar target organ), while higher tier hazard assessments may
incorporate more refined information on MOA or utilize physiologically-based pharmacokinetic or
biologically-based dose response models that may allow for probabilistic estimates of hazard.

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4 CHARACTERIZATION OF CUMULATIVE RISK UNDER TSCA

In the Risk Evaluation Rule, EPA did not codify any specific risk characterization method (see 40 CFR
702.431 thus allowing EPA the flexibility to select the most appropriate risk characterization method
based on the best available science and the weight of the scientific evidence, per TSCA sections 26(h)
and (i). As described in Section 3.5, when evaluating chemical substances for cumulative risk, EPA's
default approach is to rely upon an assumption of dose addition for toxicologically similar chemical
substances unless empirical evidence supports application of another approach. This default is based on
previous analyses of empirical data that have demonstrated that dose addition is broadly applicable and a
health protective assumption.

EPA regularly uses several approaches to estimate hazard or risk from exposure to multiple chemical
substances that are based on an assumption of dose addition, including the hazard index (HI), relative
potency factor (RPF), and margin of exposure (MOE) (U.S. EPA 2001. 2000. 1986). For example,
OLEM regularly uses the HI approach when evaluating multiple chemical substances in Superfund site
risk assessments (U.S. EPA. 1989). while OPP often uses the RPF and MOE approaches to evaluate
multiple pesticides when implementing the FQPA (U.S. EPA. 2002a). EPA's mixtures guidance
documents (U.S. EPA. 2000. 1986) provide detailed descriptions of these risk characterization
approaches. Consistent with Agency guidance and current practice, EPA will consider the applicability
of these approaches when conducting CRAs under TSCA. However, the Agency may consider other
applicable approaches as the science evolves or if the best available science indicates that approaches
based on response addition or integrated addition are more appropriate and are similarly or more health
protective.

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5 SUMMARY	

This draft document outlines the proposed principles of CRA as potentially conducted in support of
TSCA risk evaluations and is being made available for public comment and peer review. As described in
Section 1, EPA is not explicitly required to conduct CRAs under TSCA. However, TSCA does require
EPA to consider reasonably available information and to use the best available science to ensure that
decisions are based on the weight of the scientific evidence [15 U.S.C. § 2625(h), (i), (k)]. EPA
recognizes that for some chemical substances, the best available science may indicate that the
development of a CRA is appropriate to ensure that risk is adequately characterized.

At this time, EPA is proposing to focus its CRA efforts on evaluating human health (not ecological taxa)
following exposure to two or more chemical substances. As described in Section 3.4, toxicological
similarity and evidence of co-exposure over a relevant timeframe will be the principal considerations
when determining a cumulative chemical group for CRA under TSCA. Chemical groupings for CRA
will be developed using a weight of evidence approach that characterizes the strengths and uncertainties
of the evidence of toxicological similarity and potential co-exposure for each chemical substance
considered. Consistent with Agency mixtures guidances (U.S. EPA 2000. 1986). EPA will evaluate
toxicologically similar chemical substances under an assumption of dose additivity when conducting
CRAs in support of TSCA, unless empirical evidence supports application of another approach (see
Section 3.5).

EPA is soliciting comments from the SACC on charge questions and comments from the public for the
SACC meeting scheduled on May 8-11, 2023.

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6 REFERENCES	

European Commission. (2009). State of the art report on mixture toxicity - Final report. Brussels,
Belgium: European Commission.

https://ec.europa.eu/environment/chemicals/effects/pdf/report mixture toxicitv.pdf
Meek. ME: Boobis. AR; Croft on. KM: Heinemever. G: Raaii. MY: Vickers. C. (2011). Risk assessment
of combined exposure to multiple chemicals: A WHO/IPCS framework. Regul Toxicol
Pharmacol 60. http://dx.doi.Org/10.1016/i.yrtph.2011.03.010
NRC. (1994). Science and judgment in risk assessment. Washington, DC: The National Academies

Press, http://dx.doi.org/10.17226/2125
NRC. (2008). Phthalates and cumulative risk assessment: The task ahead. Washington, DC: National

Academies Press, http://dx.doi.org/10.17226/12528
NRC. (2009). Science and decisions: Advancing risk assessment. Washington, DC: National Academies

Press, http://dx.doi.org/10.17226/12209
OECD. (2018). Considerations for assessing the risks of combined exposure to multiple chemicals (No.
296). In Series on Testing and Assessment No 296. Paris, France.
http://dx.doi. org/10.178 7/ceca 15 a9-en
U.S. EPA. (1986). Guidelines for the health risk assessment of chemical mixtures. Fed Reg 51: 34014-
34025.

U.S. EPA. (1989). Risk Assessment Guidance for Superfund (RAGS): Volume 1: Human health

evaluation manual (part A): Interim final [EPA Report], (EPA/540/1-89/002). Washington, DC:
U.S. Environmental Protection Agency, Office of Emergency and Remedial Response.
https://www.epa.gov/risk/risk-assessment-guidance-superfund-rags-part
U.S. EPA. (1991). Guidelines for developmental toxicity risk assessment. Fed Reg 56: 63798-63826.
U.S. EPA. (1999). Guidance for identifying pesticide chemicals and other substances that have a

common mechanism of toxicity. Washington, DC. https://www.epa.gov/sites/default/files/2015-
07/documents/guide-2-identify-pest-chem O.pdf
U.S. EPA. (2000). Supplementary guidance for conducting health risk assessment of chemical mixtures
(pp. 1-209). (EPA/630/R-00/002). Washington, DC: U.S. Environmental Protection Agency,
Risk Assessment Forum, http://cfpub.epa.gov/ncea/cfm/recordisplav.cfm?deid=20533
U.S. EPA. (2001). General principles for performing aggregate exposure and risk assessments [EPA
Report], Washington, DC. https://www.epa.gov/pesticide-science-and-assessing-pesticide-
risks/general-principles-performing-aggregate-exposure
U.S. EPA. (2002a). Guidance on cumulative risk assessment of pesticide chemicals that have a common

mechanism of toxicity [EPA Report], Washington, D.C.

U.S. EPA. (2002b). A review of the reference dose and reference concentration processes.

(EPA630P02002F). Washington, DC. https://www.epa.gov/sites/production/files/2014-
12/documents/rfd-final.pdf
U.S. EPA. (2003). Framework for cumulative risk assessment [EPA Report], (EPA/630/P-02/00IF).
Washington, DC. https://www.epa.gov/sites/production/files/2014-
11/documents/frmwrk cum risk assmnt.pdf
U.S. EPA. (2007). Concepts, methods, and data sources for cumulative health risk assessment of

multiple chemicals, exposures, and effects: A resource document [EPA Report], (EPA/600/R-
06/013F). Cincinnati, OH. http://cfpub.epa. gov/ncea/cfm/recordisplay.cfm?deid= 190187
U.S. EPA. (2011). Pyrethrins/pyrethroid cumulative risk assessment. Washington, DC: Office of

Pesticide Programs. https://www.regulations.gov/document/EPA-HQ-QPP-2011 -0746-0019
U.S. EPA. (2016). Pesticide cumulative risk assessment: Framework for screening analysis.

Washington, DC: Office of Pesticide Programs, https://www.epa.gov/pesticide-science-and-
assessing-pesticide-risks/pesticide-cumulative-risk-assessment-framework

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592	U.S. EPA. (2019). Guidelines for human exposure assessment [EPA Report], (EPA/100/B-19/001).

593	Washington, DC: Risk Assessment Forum. https://www.epa.gov/sites/production/files/202Q-

594	01/documents/guidelines for human exposure assessment final2019.pdf

595	U.S. EPA. (2022). Cumulative impacts: Recommendations for EPA's Office of Research and

596	Development. (EPA/600/R-22/014a). Washington, DC: Office of Research and Development,

597	U.S. Environmental Protection Agency.

598	https://heronet.epa.gov/heronet/index.cfm/reference/download/reference id/10555212

599

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Appendix A GLOSSARY OF KEY TERMS	

Additivity (U.S. EPA. 2007. 2000): "when the effect of the combination of chemicals can be estimated
directly from the sum of the scaled exposure levels (dose addition) or of the responses (response
addition) of the individual components."

Aggregate exposure (40 CFR § 702.33): "means the combined exposures to an individual from a single
chemical substance across multiple routes and across multiple pathways."

Best available science (40 CFR § 702.33): "means science that is reliable and unbiased. Use of best
available science involves the use of supporting studies conducted in accordance with sound and
objective science practices, including, when available, peer reviewed science and supporting studies and
data collected by accepted methods or best available methods (if the reliability of the method and the
nature of the decision justifies use of the data). Additionally, EPA will consider as applicable:

(1)	The extent to which the scientific information, technical procedures, measures, methods,
protocols, methodologies, or models employed to generate the information are reasonable for and
consistent with the intended use of the information;

(2)	The extent to which the information is relevant for the Administrator's use in making a decision
about a chemical substance or mixture;

(3)	The degree of clarity and completeness with which the data, assumptions, methods, quality
assurance, and analyses employed to generate the information are documented;

(4)	The extent to which the variability and uncertainty in the information, or in the procedures,
measures, methods, protocols, methodologies, or models, are evaluated and characterized; and

(5)	The extent of independent verification or peer review of the information or of the procedures,
measures, methods, protocols, methodologies or models."

Biomonitoring (U.S. EPA. 2019): "measures the amount of a stressor in biological matrices."

Category of chemical substances (15 U.S.C. § 2625(c)(2)(A)): "means a group of chemical substances
the members of which are similar in molecular structure, in physical, chemical, or biological properties,
in use, or in mode of entrance into the human body or into the environment, or the members of which
are in some other way suitable for classification as such for purposes of [TSCA], except that such term
does not mean a group of chemical substances which are grouped together solely on the basis of their
being new chemical substances."

Chemical substance (15 U.S.C. § 2602(2)): "means any organic or inorganic substance of a particular
molecular identity, including—(i) any combination of such substances occurring in whole or in part as a
result of a chemical reaction or occurring in nature, and (ii) any element or uncombined radical. Such
term does not include—(i) any mixture, (ii) any pesticide (as defined in the Federal Insecticide,
Fungicide, and Rodenticide Act [7 U.S.C. 136 et seq.]) when manufactured, processed, or distributed in
commerce for use as a pesticide, (iii) tobacco or any tobacco product, (iv) any source material, special
nuclear material, or byproduct material (as such terms are defined in the Atomic Energy Act of 1954 [42
U.S.C. 2011 et seq.] and regulations issued under such Act), (v) any article the sale of which is subject
to the tax imposed by section 4181 of the Internal Revenue Code of 1986 [26 U.S.C. 4181] (determined
without regard to any exemptions from such tax provided by section 4182 or 4221 or any other
provision of such Code) and any component of such an article (limited to shot shells, cartridges, and
components of shot shells and cartridges), and (vi) any food, food additive, drug, cosmetic, or device (as

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such terms are defined in section 201 of the Federal Food, Drug, and Cosmetic Act [21 U.S.C. 321])
when manufactured, processed, or distributed in commerce for use as a food, food additive, drug,
cosmetic, or device."

Condition of use (COU) (40 CFR § 702.33): "means the circumstances, as determined by the
Administrator, under which a chemical substance is intended, known, or reasonably foreseen to be
manufactured, processed, distributed in commerce, used, or disposed of."

Consumer exposure (40 CFR § 711.3): Human exposure resulting from consumer use. This exposure
includes passive exposure to consumer bystanders.

Consumer use (40 CFR § 711.3): "means the use of a chemical substance or a mixture containing a
chemical substance (including as part of an article) when sold to or made available to consumers for
their use."

Cumulative impacts (U.S. EPA 2022): "are defined as the totality of exposures to combinations of
chemical and non-chemical stressors and their effects on health, well-being, and quality of life
outcomes."

Cumulative impacts assessment (U.S. EPA 2022): "a process of evaluating both quantitative and
qualitative data representing cumulative impacts to inform a decision."

Cumulative risk (U.S. EPA 2003): "The combined risks from aggregate exposures to multiple agents
or stressors."

Cumulative risk assessment (CRA) (U.S. EPA 2003): "An analysis, characterization, and possible
quantification of the combined risks to health or the environment from multiple agents or stressors."

Dose additivity (U.S. EPA 2007. 2003. 2000): when each chemical behaves as a concentration or
dilution of every other chemical. The response of the combination of chemicals is the response expected
from the equivalent dose of an index chemical (the chemical selected as a basis for standardization of
toxicity of components in a mixture). The equivalent dose is the sum of component doses scaled by their
toxic potency relative to the index chemical."

Fenceline exposure: General population exposures occuring in communities near facilities that emit or
release chemicals to air, water, or land with which they may contact.

Integrated addition: a hybrid additivity approach that incorporates both dose addition and response
addition for dichotomous endpoints, thus, producing a mixture estimate that is the probabilistic risk of
the adverse endpoint of concern.

Margin of exposure (MOE) (U.S. EPA. 2002a): "a numerical value that characterizes the amount of
safety to a toxic chemical-a ratio of a toxicological endpoint (usually a NOAEL [no observed adverse
effect level]) to exposure. The MOE is a measure of how closely the exposure comes to the NOAEL."

Mixture (15 U.S.C. § 2602(10)): "means any combination of two or more chemical substances if the
combination does not occur in nature and is not, in whole or in part, the result of a chemical reaction;
except that such term does include any combination which occurs, in whole or in part, as a result of a

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chemical reaction if none of the chemical substances comprising the combination is a new chemical
substance and if the combination could have been manufactured for commercial purposes without a
chemical reaction at the time the chemical substances comprising the combination were combined."

Mode of Action (MOA) (U.S. EPA. 2000): "a series of key events and processes starting with
interaction of an agent with a cell, and proceeding through operational and anatomical changes causing
disease formation."

Non-chemical stressors (U.S. EPA. 2022): "Non-chemical stressors are factors found in the built,
natural, and social environments including physical factors such as noise, temperature, and humidity and
psychosocial factors (e.g., poor diet, smoking, and illicit drug use)"

Non-TSCA exposure: exposure that can be attributed to specific activities that are excluded from the
TSCA definition of "chemical substance," under TSCA Section 3(2), such as a pesticide, food, food
additive, drug, cosmetic, or medical device.

Occupational non-users (ONU): Employed persons who do not directly handle the chemical substance
but may be indirectly exposed to it as part of their employment due to their proximity to the substance.

Pathways (40 CFR § 702.33): "means the mode through which one is exposed to a chemical substance,
including but not limited to: Food, water, soil, and air."

Point of departure (POD) (U.S. EPA. 2002a): "dose that can be considered to be in the range of
observed responses, without significant extrapolation. A POD can be a data point or an estimated point
that is derived from observed dose-response data. A POD is used to mark the beginning of extrapolation
to determine risk associated with lower environmentally relevant human exposures."

Potentially exposed or susceptible subpopulations (PESS) (15 U.S.C. § 2602(12)): "means a group of
individuals within the general population identified by the Agency who, due to either greater
susceptibility or greater exposure, may be at greater risk than the general population of adverse health
effects from exposure to a chemical substance or mixture, such as infants, children, pregnant women,
workers, or the elderly."

Reasonably available information (40 CFR § 702.33): "means information that EPA possesses or can
reasonably generate, obtain, and synthesize for use in risk evaluations, considering the deadlines
specified in TSCA section 6(b)(4)(G) for completing such evaluation. Information that meets the terms
of the preceding sentence is reasonably available information whether or not the information is
confidential business information, that is protected from public disclosure under TSCA section 14."

Response addition (U.S. EPA. 2007. 2003. 2000): "When the toxic response (rate, incidence, risk, or
probability of effects) from the combination is equal to the conditional sum of component responses as
defined by the formula for the sum of independent event probabilities. For two chemical mixtures, the
body's response to the first chemical is the same whether or not the second chemical is present."

Routes (40 CFR § 702.33): "means the particular manner by which a chemical substance may contact
the body, including absorption via ingestion, inhalation, or dermally (integument)"

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PUBLIC COMMENT DRAFT - DO NOT CITE OR QUOTE

Sentinel exposure (40 CFR § 702.33): "means the exposure from a single chemical substance that
represents the plausible upper bound of exposure relative to all other exposures within a broad category
of similar or related exposures."

Stressor (U.S. EPA. 2019): "Any chemical, physical or biological entity that induces an adverse
response."

Toxicologic interactions (U.S. EPA 2007. 2000): "Any toxic responses that are greater than or less
than what is observed under an assumption of additivity."

Weight of the scientific evidence (40 CFR § 702.33): "means a systematic review method, applied in a
manner suited to the nature of the evidence or decision, that uses a pre-established protocol to
comprehensively, objectively, transparently, and consistently, identify and evaluate each stream of
evidence, including strengths, limitations, and relevance of each study and to integrate evidence as
necessary and appropriate based upon strengths, limitations, and relevance."

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