CPR President Rena Steinzor and Senior Policy Analyst Matthew Shudtz sent a letter to EPA Administrator Lisa Jackson this morning concerning the EPA’s Integrated Risk Information System (IRIS). From the letter:
We are concerned that the recent establishment of the SAB Chemical Assessment Advisory Committee (CAAC) institutionalizes yet another opportunity for potentially regulated parties to disrupt the smooth development of new IRIS profiles. We are writing to encourage you to pay special attention to the nominees’ actual and perceived conflicts of interest as you sign off on the final membership list for the subcommittee. Of the 116 nominees, we count only four individuals who work for environmental NGOs. By contrast, five individuals from the Dow Chemical Company alone have been nominated, as have five other people employed by potentially regulated parties and 21 individuals whose consultancy firms stand to gain or lose significant business depending on the outcome of CAAC deliberations. … Individuals whose employers (or employers’ direct competitors) are potentially regulated parties should not be invited to be committee members.
The letter makes a broader point about the role of further review of IRIS profiles, which undergo at least seven reviews by people or entities outside the IRIS office:
For years, we have argued that the draft toxicological profiles produced by IRIS staff are subject to an excessive number of external reviews. … Given the Federal Advisory Committee Act’s requirements about transparency and public participation, we believe that the CAAC review of draft IRIS profiles should replace the independent expert peer review and be melded with the listening session and public review and comment period.
The letter is here.