On July 18, 2016, CRE submitted to EPA and the U.S. Department of Agriculture a Request for Joint Development of Standard Operating Procedures If Epidemiological Data is used in Pesticide Assessment and Registration.
CRE’s request is prompted by EPA’s recent attempt to use Epi data during pesticide actions in an ad hoc manner that violates Data Quality standards. CRE agrees with USDA that standard operating procedures need to be developed before EPA uses Epi data for pesticides.
CRE’s request explains in part:
“The U.S. Environmental Protection Agency has rarely used epidemiological data to assess and register pesticides under FIFRA. The Department of Agriculture correctly explained to the EPA that, ‘if epidemiological studies are to form the basis of the FQPA factor, a new standard operating procedure is needed.’ These new procedures should not be limited to pesticide safety factors because Standard Operating Procedures are necessary for any use of epidemiological data during pesticide assessment and registration.
The aforementioned procedures should be developed through public notice and comment procedures. Furthermore, they should be externally peer reviewed and developed in close cooperation with the USDA.
This is the best and perhaps only way to ensure that pesticide epidemiological data comply with the Data (Information) Quality Act (‘DQA’) and with related EPA quality requirements. Prudent use of the DQA is a proven way to produce scientifically sound conclusions.”