CRE Comments at EDSP Weight of Evidence SAP

On July 30, 2013, CRE presented oral and written comments to the FIFRA Science Advisory Panel which is reviewing EPA’s Weight of Evidence approach to evaluating results from the EDSP Tier 1 screening. For several reasons, CRE asked the SAP to recommend that EPA not use any EDSP Tier 1 test data to determine who has to perform EDSP Tier 2 tests. Among those reasons are:

 ●The EDSP Tier 1 test battery includes the Amphibian Metamorphosis Assay (“AMA”). A SAP in May 2013 recommended that EPA not use the AMA because there are significant problems with the AMA test results for the first set of EDSP Tier 1 chemicals.

CRE Opposes ICR for Additional Chemicals

EPA has asked OMB/OIRA to approve EPA’s Information Collection Request for use of the EDSP Tier 1 test battery on additional chemicals. CRE’s comments asked OMB/OIRA not to approve this ICR for several reasons. For example, the EDSP Tier 1 test battery includes the Amphibian Metamorphosis Assay.  A recent Science Advisory Panel recommended that EPA not use the AMA for any additional chemicals because its test results to date have too many problems and flaws.   Click here to read CRE’s comments.