Stoffenmanager and ART are recommended by ECHA for occupational exposure assessment. However, we have found fundamental errors both from Stoffenmanager and ART [1,2,3] and the models predictability has been shown to be very poor by many studies (see e.g. presentation in at . Because of this, the models do not fulfill requirements for regulatory safety decision making tool. How it is possible that European Commission allows use of non-physical models in regulatory safety decision making which variation in exposure predictability is >100 000 (i.e. measured value 1 mg/m3, predicted value vary from 0.001 to 100 mg/m3)?
I would like to raise more discussion from this challenging topic and public awareness of the errors. This is because model developers and owners do not want to have this discussion.
With Kind regards,