On July 30, 2013, CRE presented oral and written comments to the FIFRA Science Advisory Panel which is reviewing EPA’s Weight of Evidence approach to evaluating results from the EDSP Tier 1 screening. For several reasons, CRE asked the SAP to recommend that EPA not use any EDSP Tier 1 test data to determine who has to perform EDSP Tier 2 tests. Among those reasons are:
●The EDSP Tier 1 test battery includes the Amphibian Metamorphosis Assay (“AMA”). A SAP in May 2013 recommended that EPA not use the AMA because there are significant problems with the AMA test results for the first set of EDSP Tier 1 chemicals.