Comment Period - Announcement of the Developmental and Reproductive Toxicant Identification Committee Meeting; Notice of Availability of Hazard Identification Materials for Perfluorononanoic Acid and Perfluorodecanoic Acid and Their Salts

The document accurately presents the effects of PFDA and PFNA on the reproductive endpoints described in the literature. However, in the document there is no discussion of the degree effects of these PFAS on growth, body weight, systemic toxicity and mortality. Many, if not all of the cited reproductive effects are concurrent with body weight reductions, some as large as as 55% reduction in terminal weight versus control and mortality with PFNA and body weight reductions as large as 38% with PFDA (PFNA 5 and 10 mg/kg/d TP 28 day study). Does CA typically consider effects on the reproductive system to be evidence of reproductive toxicity if they only occur at dose levels also producing overt toxicity?