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.
●The EDSP Tier 1 test battery is designed to be conducted as a whole to determine the potential of a chemical to interact with the E, A, or T hormonal pathways. Each assay is critical to the utility of the entire battery as an endocrine disruptor screen. Consequently, loss of the AMA precludes utility for the rest of the battery. In EPA’s own words, the AMA is an “essential” component of the EDSP Tier 1 test battery.
●Consequently, the current EDSP Tier 1 test data do not provide an accurate and reliable basis for determining who should perform EDSP Tier 2 testing.
Click here to read CRE’s comments.