“…More importantly, these RSCs are more than three orders of magnitude below airborne concentrations equivalent to endogenously produced EO, in the general nonsmoking population (mean concentrations of ~1.9 and 2.9 ppb) based on data evaluated by Kirman and Hays [ 2 ], based on data from published unexposed control subjects [ 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17 ] and Kirman et al [ 3 ], and based on data from nonsmoking U.S. individuals [ 4 ], respectively. For additional perspective, as described by Bogen et al [ 7 ], these RSCs are up to seven orders of magnitude below the levels of EO to which 1930s–1970s sterilization operators and other highly exposed sterilization workers in the National Institute for Occupational Safety and Health (NIOSH) cohort used by EPA in its risk assessment were exposed (50,000 to >100,000 ppb). Based on these comparisons, it is obvious that the EPA RSCs are incapable of providing useful benchmarks to evaluate the health significance of such low general population EO exposures.…”