CRE’s comments included the following points.

First, CRE supports and commends EPA’s efforts to provide High Throughput Assays (HTP) and Toxicity Forecaster (ToxCast) as an alternative to the current EDSP Tier 1screening assays.

Second, EPA should not require products that have already undergone current Tier 1 screening to be rescreened and/or reevaluated through HTP and ToxCast.

Third, EPA should have another Science Advisory Panel review EPA’s conclusions about HTP/ToxCast and the Current Tier 1 uterotrophic screening assay.

Fourth, EPA needs to produce a white paper that clearly and comprehensively explains the EDSP validation process, including EPA’s standards for validation, and that explains why EPA believes that HTP/ToxCast has been demonstrated accurate, reliable and reproducible for the ER and uterotrophic EDSP Tier 1 screening assays. The current administrative record on this issue is fragmented, incomplete and difficult to follow.

Click here to read CRE’s entire comments.