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CRE Comments on EPA's Pollinator Risk Assessment Framework
On August 28, 2012, the Center for Regulatory Effectiveness filed comments with EPA on the FIFRA Scientific Advisory Panel Public Meeting on EPA's Pollinator Risk Assessment Framework. This SAP will meet on September 11-14, 2012.
CRE's comments are available online at http://www.thecre.com/oira_pd/?p=110. They apply a Data Quality Act analysis to this SAP's review, and they include the following summary:
"1. The Data Quality Act and its guidelines apply to studies and data authored or collected by outside (or 'third-party') entities. The agency will not be able to use such studies or data in a risk assessment unless they can meet the law's quality standards.
2. The SAP and the agency should be fully informed on the requirements of the DQA and its guidance, particularly the definitions of 'objectivity,' 'utility,' and 'reproducibility.'
3. There are studies being touted in the media as 'convincing,' such as the very recent Lu et al. study from Harvard, that clearly cannot meet DQA standards, and therefore cannot be used by the agency to support risk assessment conclusions.
4. The subject pollinator risk assessment 'framework' is intended to provide the foundation for, or be the first step in, a 'highly influential' agency risk assessment subject to the DQA peer review guidance. Therefore, the SAP and the agency should begin applying the DQA guidance at this stage. One requirement of the peer review guidance of particular importance is that peer reviews should appraise scientific data objectively, and should not inject non-scientific, or 'policy,' considerations, into their judgments. The peer review guidance also affirms the need for peer reviews to adhere to all the DQA quality standards.
5. It is doubtful whether the Pettis study could be used by EPA since it is probably non-compliant with the DQA.
6. The SAP should focus on the role of Varroa mites in bee health decline. An enhanced understanding of the role Varroa mites would be common to all bee health decline strategies.
7. The SAP risk assessment regime should include an analytical survey which is DQA compliant that delineates the magnitude of the bee health decline."