The American Chemistry Council (ACC), a trade association that represents chemical industry interests and is heavily connected to the plastics industry, filed a Request for Correction Monday on the EPA's Chemical Action Plan for Bisphenol A (BPA). The request, filed under a provision of the Data Quality Act (also referred to as the Information Quality Act), is truly astonishing and bears noting. In addition to standard requests that EPA statements be toned down or removed due to conflicting studies, ACC makes several requests that EPA remove statements that are included not as “ knowledge such as facts or data,” but policy statements that reflect EPA’s intent to manage exposure to BPA.
ACC requests in several places that references to a Canadian risk assessment of BPA be deleted because the Canadian assessment was informed by the precautionary principle:
Any reliance in the Canadian assessment to support EPA’s conclusion that … action is warranted is not appropriate under the Guidelines; EPA cannot blindly rely on Canada’s screening risk assessment (particularly as Canada’s assessment incorporates the precautionary principle), but must perform its own weight-of-the-evidence assessment. (p. 9)
And ACC later objects to the use of a “conservative” model:
EPA cannot rely on the highly conservative E-FAST2 modeling of BPA releases in the 2007 TRI to estimate the amount of BPA in drinking water or surface water when there exists [sic] peer-reviewed assessments of BPA in groundwater and drinking water… (p. ...