On September 26, 2012, the Center for Regulatory Effectiveness submitted comments on EPA’s draft Framework for Human Health Risk Assessment to Inform Decision Making. CRE’s comments included the following points:

● The Framework should be revised to reference and discuss EPA’s Information Quality  Guidelines requirements for risk assessments.

● The Framework should be revised to reference and discuss the Office of Management and Budget’s Memorandum on Updated Principles for Risk Analysis.

● The Framework should be revised to reference and discuss EPA’s Council for Regulatory Environmental Modeling Guidance on the Development, Evaluation, and Application of Environmental Models.

● The Framework should be revised to reference and discuss the other modeling guidance on EPA’s CREM website.

●EPA’s Risk Assessment Portal should be revised to reference and link to the IQA, CREM and OMB Memorandum discussions in the final Framework.

●EPA’s Risk Assessment Guidance and Tools website should be revised to reference and link to the IQA, CREM and OMB Memorandum discussions in the final Framework.

Click here to read CRE’s comments