CRE Comments on Atrazine PID
On February 29, 2020, the Center for Regulatory Effectiveness filed comments on EPA’s Proposed Interim Decision on the atrazine FIFRA re-registration. CRE’s comments make the following and other points.
CRE commends EPA’s PID for improved data quality in some respects. In particular, the PID’s Community Equivalent Level of Concern (“CELOC’) is superior to the grossly flawed CELOC that EPA included in the Agency’s Ecological Risk Assessment for atrazine. We request that EPA emphasize in the record that the new 15 ppb CELOC applies to all watersheds. We also request that EPA not use either the new or old CELOC quantitatively or qualitatively for “final effects determinations.”
We also comment on several significant data quality flaws and omissions in the ERA. For example, EPA’s atrazine Ecological Risk Assessment states that EPA is considering atrazine amphibian studies “with quality concerns and [which] have not been replicated since the original study, despite multiple studies involving the same endpoint.” EPA’s reliance on amphibian effects studies that are of poor-quality and demonstrated to be non-reproducible violates the Information Quality Act’s (”IQA”) accuracy and reproducibility requirements. We request that EPA not use any non-reproducible studies to assess or regulate atrazine or any other product.
We point out that the ERA violates IQA requirements in several other respects: e.g., use of inaccurate, unvalidated models and inaccurate statements such as 35% bird deaths from atrazine use.
EPA should expect an IQA Request for Correction (“RFC”) if the atrazine ERA is not corrected in a timely manner to comply with the IQA. These corrections include but are not limited to stop using non-reproducible, inaccurate and unreliable studies to assess and regulate atrazine.
We hope for data quality improvement during EPA’s Endangered Species Act review and consultation using new EPA’s “Draft Revised Method for National Level Endangered Species Risk Assessment Process for Biological Atrazine ECO Risk Assessment Evaluations of Pesticides.” EPA’s ESA and other atrazine review should be consistent with the quality standards identified in CRE ‘s filings with the Agency on the issue.
Click here to read CRE’s filed comments on EPA’s atrazine PID.