Comments on Five IRIS Assessments Show Industry Clogging up Process with Not Relevant Information

One of the biggest challenges for the EPA’s Integrated Risk Information System (IRIS), a database for toxicological information and human health effects data that plays a role in many regulatory safeguards, is how slowly it produces chemical assessments. One of the reasons: chemical industry interests have flooded the comments on many IRIS assessments with pages of non-germane information for EPA to wade through.

In a letter today to EPA Administrator Lisa Jackson, CPR President Rena Steinzor and Policy Analysts Wayland Radin and Matthew Shudtz urge the agency to put reasonable limits on IRIS comments. They looked at 70 comments on 5 recent IRIS assessments (totaling 2800 pages, with attachments), and found that “ interested parties, particularly industry trade associations, frequently submit comments that do not provide relevant and timely information to EPA, but rather waste EPA’s time and resources and delay badly needed public protections.”

The dockets in the five assessments included comments that were redundant, raised non-germane issues, called for reconsideration of settled issues, or were unnecessarily long submissions. From the letter:

We recommend that EPA take strong steps to establish more effective filters on the deliberate loading of the record with redundant and irrelevant information.  The agency should develop criteria for submitting comments and, if submitters do not voluntarily comply with this guidance, the agency should excise the documents filed by egregious violators from consideration.  EPA is no less entitled than the judiciary to control the manner in which commenters appear before it to make their arguments.  The courts have developed limits on the scope, format, and content of such submissions that greatly facilitate their timely decision-making.