Auto Innovators submitted comments to EPA on the revised risk determination for HBCD to address the following. (1) Confirm that uses are limited to replacement parts only and emphasizing that replacement parts should be exempted per the provisions of TSCA, and (2) Raise significant concerns with EPA’s new policy approaches, including a whole chemical approach and assumptions that PPE are not used in workplaces. These new approaches jeopardize the preemption provisions in TSCA, and complicate the next step of risk management, by pulling in nearly all uses to be addressed. A copy of the comments submitted by the Downstream Users Coalition are also attached.