Comment submitted on behalf of Pensalab

1. The solvent-less D7575 method like EPA 1664 requires cumbersome sample handling which is not ideal as an on-site method. D7066 was developed specifically for either on-site or laboratory use. 2. On-site methods can avoid economically and environmentally costly delays which could be incurred while waiting for off-site results 3. D7066 is based on well-established EPA 413.2 and 418.1 methods, used worldwide for over 35 years. The primary difference is the use of in the non-ODS solvent in D7066 for the extraction.