Tier 1 of EPA’s Endocrine Disruptor Screening Program focuses on pesticides.  EPA recently published a Weight of Evidence guidance document to be used in assessing Tier 1 test results from the EDSP. The WoE document is available online at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2010-0877-0021 .

EPA has also published Standard Evaluation Procedures to be used during Tier 1 of the EDSP. [1] The SEPs are available online at http://www.epa.gov/endo/pubs/toresources/seps.htm .

CRE recently sent a letter to EPA objecting to these two documents. CRE’s letter stated our understanding that the SEPs have never been peer reviewed in any way, and that the WoE has only been internally peer reviewed by EPA employees.  The record of the WoE internal peer review is not publicly available. If CRE’s understanding is correct, then the WoE and SEP violate the requirements of OMB’s Peer Review Bulletin and OMB’s Terms of Clearance for the EDSP Information Collection Request.

CRE’s letter requests that EPA not use the WoE or the SEPs until and unless they have been peer reviewed in a manner that complies with OMB’s requirements.

● CRE’s letter to EPA is attached below