EPA’s Integrated Risk Information System (IRIS) is now requesting that persons who make oral comments at its bimonthly meetings or submit written comments on its documents disclose whether they have “financial relationships … with any organization(s) or entities having an interest in the assessments or issues under discussion,” and, if so, to identify the nature of that relationship, (e.g., consulting agreements, expert witness support, or research funding). Read More
Selected tag(s): industry tactics
EDF’s recommendations for IRIS conflicts-of-interest disclosures, and the strong precedents for them
Our last blog post was quite lengthy and some readers may not have gotten to the recommendations we provided to EPA’s Integrated Risk Information System (IRIS) governing disclosures of conflicts of interest. In that post, we also cited the numerous strong precedents for requiring such disclosures.
So we’re reposting here our recommendations and discussion of precedents. Read More
Time to come clean: IRIS needs to require stakeholders attending its meetings to disclose their conflicts of interest
EPA’s Integrated Risk Information System (IRIS) has been implementing a number of changes in the last couple of years, in response to criticism and concerns coming at it from all sides. As stated on its website: “These enhancements will improve productivity and scientific quality in IRIS assessments and help EPA meet the goal of producing IRIS assessments in a timely and transparent manner.” IRIS has noted that increasing “stakeholder engagement is an essential part of the enhancements.”
Simultaneously pursuing these lofty goals of increasing throughput, scientific quality, transparency and stakeholder engagement in IRIS assessments is challenging, to say the least. EDF has and will continue to emphasize the need to strike a balance between these goals, given that overemphasis on one can actually exacerbate the problems aimed to be addressed by another.
In this somewhat lengthy post, we’ll examine one such serious problem – skewed participation in IRIS’ bimonthly meetings. We’ll look at steps EPA has taken to partially address the problem, and argue that the lack of adequate disclosure by participants of conflicts of interest remains a major unaddressed contributing factor. We’ll discuss our recommendations for full disclosure and point to the strong precedents for such disclosures in other venues. Read More
Twice in 2 weeks: National Academy of Sciences again strongly affirms federal government’s science, agrees formaldehyde is a known human carcinogen
Richard Denison, Ph.D., is a Lead Senior Scientist.
Just last week I blogged that a panel of the National Academy of Sciences (NAS) had fully backed the National Toxicology Program’s (NTP) listing of styrene as “reasonably anticipated to be a human carcinogen.”
Today a separate NAS panel strongly endorsed NTP’s listing of formaldehyde as a “known human carcinogen” in its 12th Report on Carcinogens (RoC). As with styrene, this second NAS panel both peer-reviewed the RoC listing and conducted its own independent review of the formaldehyde literature – and in both cases found strong evidence to support NTP’s listing. See the NAS press release here, which links to the full report. Read More
Richard Denison, Ph.D., is a Lead Senior Scientist. Rachel Shaffer is a research assistant.
[UPDATE 6/24/14: Perhaps in response to this post of last week, an updated agenda for this week's IRIS meeting was posted by EPA today that reflects a somewhat more balanced set of speakers. Industry interests appear to have consolidated their number of slots, down from a high of 8 to a high of 6 per issue, and down from a high of 6 to a high of 4 individuals per issue from the same consulting firm. In addition, several additional slots are assigned to non-industry speakers. If you wish to see the changes, here is the agenda we linked to that was current as of last week, and here's the updated agenda posted today.]
In comments EDF made at a November 2012 stakeholder meeting held by EPA’s Integrated Risk Information System (IRIS) program, we warned that the tendency of the IRIS program to respond to criticism by expanding opportunities for “public” input would serve to increase rather than decrease the imbalance in stakeholder input.
We noted that providing more opportunities for participation not only lengthens the timeline for completing assessments; it also virtually ensures the input received by EPA is imbalanced and badly skewed toward the regulated community. That’s because companies that produce and use each chemical to be assessed – and the trade associations and myriad hired consultants that represent them – have a clear vested financial interest in the outcome of the assessment. They can and will take advantage of each and every opportunity for input, and they will be better represented than other stakeholders each and every time.
IRIS recently began holding bimonthly meetings focused on “key science issues” relating to upcoming assessments. And guess what? An army of industry representatives, including staff for trade associations and paid consultants, are overwhelming the agendas.
Exhibit A: Have a quick look at the list of speakers in the agenda for this month’s bimonthly meeting. A striking imbalance, no? As many as 8 industry representatives are set to speak on a given issue, including 6 from the same consulting firm! [UPDATE 6/24/14: See the top of this post for a description of the updated, slightly more balanced agenda; here is the agenda we had linked to that was current as of last week, and here's the updated agenda posted today.] Read More
Richard Denison, Ph.D., is a Senior Scientist.
The Environmental Protection Agency (EPA) has withdrawn two draft rules it had developed under authority of the Toxic Substances Control Act (TSCA). EPA originally sent the proposed rules to the White House for its review way back in 2010 and 2011.
Despite a clear requirement that White House reviews of draft proposed rules be completed within 90 days, the Office of Information and Regulatory Affairs (OIRA) [which is part of the Office of Management and Budget, OMB] sat on these two draft proposals for 1,213 and 619 days, respectively. Faced presumably with the reality that OIRA was never going to let EPA even propose the rules for public comment, EPA decided to withdraw them. Read More