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®: CRE Regulatory Action of the Week

CRE comments to OIRA on Its Draft Regulatory Report to Congress
OMB has invited public comment on its draft report to Congress under the Regulatory Right-to-Know Act. Comments are due by April 3. One of the subjects on which comments were requested is risk assessment approaches "which appear unbalanced." CRE filed comments which focus on EPA's "interim" policy for rejecting "third-party" human volunteer test data as an example of an "unbalanced" risk assessment approach. The CRE comments also address more generic issues involved with the EPA policy that concern avoidance of OIRA review of a regulatory action by labeling it a "policy" and failing to publish it in the Federal Register, and also designating it as an "interim" position. CRE recommends that OIRA review the appropriateness of the policy and issue new guidance on what constitutes a "regulatory action" subject to E.O. 12866 review, and guidance on when an "interim" policy should be considered a final regulatory action.

  • Click to read the CRE comments
  • Click to read Attachment 1 to CRE's comments
  • Click to read Attachment 2 to CRE's comments
  • Click to read Attachment 3 to CRE's comments
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