Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

This example raises some new issues as well as some we discussed in the earlier examples:  EPA relies on a highly flawed “category approach” that ignores major differences in the properties and structures of the 13 members of this category.  It compounds this problem by unquestioningly accepting data from inadequate studies to assert low toxicity, rather than demanding that sufficient studies be provided.  As a result, it fails to identify, let alone require to be filled, the enormous gaps in the data available for many of the category members.  EPA ignores or dismisses without explanation its own earlier comments raising serious concerns about the quality and completeness of data provided by the sponsor of these chemicals under the HPV Challenge.  Finally, this example once again shows how EPA’s heavy reliance on self-reported use information from manufacturers paints an incomplete and potentially very misleading picture of the actual uses of industrial chemicals.  Read More »