The Environmental Protection Agency has announced its intent to ask the Office of Management and Budget to authorize an extension of EPA’s current Information Collection Request for EPA’s Endocrine Disruptor Screening Program. On October 9, 2012, the Center for Regulatory Effectiveness filed comments on this ICR which made several arguments against the ICR, including the following:
- This ICR and the EDSP violate the Paperwork Reduction Act (“PRA”) because they include tests which are not the least burdensome alternative.
- This ICR and the EDSP also lack practical utility and violate the PRA because 1) many of EPA’s Tier 1 tests failed their initial peer review and have never been found to be accurate, reliable and reproducible by an expert and independent peer review panel; and 2) all the Tier 1 tests are useless because their only use is to determine whether products have to undergo Tier 2 testing, and there may never be properly validated Tier 2 tests.
- This ICR and the EDSP also violate OMB’s Terms of Clearance for the current EDSP ICR.
Click here to read’s CRE’s comments on the EDSP ICR