CRE submitted comments to EPA on the Agency’s FIFRA registration review for atrazine.  EPA is just beginning the registration review process, so CRE will probably file subsequent comments.  CRE’s comments made the following among other points.

First, EPA’s atrazine registration review should document its compliance with EPA’s Information Quality Act (“IQA”) Guidelines. For example, EPA should document that the atrazine review and any atrazine consultations under the Endangered Species Act comply with the IQA Guidelines as expounded by the National Research Council’s report Assessing Risks to Endangered and Threatened Species from Pesticides. EPA should also document that the atrazine review and any atrazine consultations under the ESA comply with EPA’s Council for Regulatory Environmental Models (“CREM”) Guidance.

Second, EPA should ensure the reproducibility of any data or studies that EPA uses or relies on in the atrazine review. Reproducibility is required by EPA’s IQA Guidelines, and EPA has emphasized the importance of reproducibility in recent communications with the NRC.

Click here to read CRE’s comments.