One of the biggest challenges for the EPA’s Integrated Risk Information System (IRIS), a database for toxicological information and human health effects data that plays a role in many regulatory safeguards, is how slowly it produces chemical assessments. One of the reasons: chemical industry interests have flooded the comments on many IRIS assessments with pages of non-germane information for EPA to wade through.
In a letter today to EPA Administrator Lisa Jackson, CPR President Rena Steinzor and Policy Analysts Wayland Radin and Matthew Shudtz urge the agency to put reasonable limits on IRIS comments. They looked at 70 comments on 5 recent IRIS assessments (totaling 2800 pages, with attachments), and found that “ interested parties, particularly industry trade associations, frequently submit comments that do not provide relevant and timely information to EPA, but rather waste EPA’s time and resources and delay badly needed public protections.”
The dockets in the five assessments included comments that were redundant, raised non-germane issues, called for reconsideration of settled issues, or were unnecessarily long submissions. From the letter:
We recommend that EPA take strong steps to establish more effective filters on the deliberate loading of the record with redundant and irrelevant information. The agency should develop criteria for submitting comments and, if submitters do not voluntarily comply with this guidance, the agency should excise the documents filed by egregious violators from consideration. EPA is no less entitled than the judiciary to control the manner in which commenters appear before it to make their arguments. The courts have developed limits on the scope, format, and content of such submissions that greatly facilitate their timely decision-making.
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Ben Somberg | November 1, 2012
One of the biggest challenges for the EPA’s Integrated Risk Information System (IRIS), a database for toxicological information and human health effects data that plays a role in many regulatory safeguards, is how slowly it produces chemical assessments. One of the reasons: chemical industry interests have flooded the comments on many IRIS assessments with pages […]
Daniel Farber | October 31, 2012
Cross-posted from Legal Planet. Today’s FEMA is a lot different from the organization that flubbed the Katrina response. There have been a number of positive changes, mostly during the past four years. First, as the Washington Post explains, FEMA’s authority has expanded: Congress has broadened FEMA’s authority so that the agency can respond in advance […]
Daniel Farber | October 29, 2012
Cross-posted from Legal Planet. The federal role in disaster response dates back to the 1906 San Francisco earthquake, when General Funston sent troops from the Presidio to deal with the city’s desperate emergency. Governor Romney seems dubious about this century-old federal role. During one of the GOP primary debates, Governor Romney was asked what he […]
Robert Verchick | October 26, 2012
If you like sparkling diamonds and saffron saris, you will love Surat, India’s bustling, no-nonsense city, some 250 kilometers north of Mumbai, near the Arabian Sea. If you’re wearing a new diamond, there’s an 80% chance its was shaped by Surati hands (and laser beams too). And nearly every Indian has something in the closet […]
Thomas McGarity | October 25, 2012
In the week before Christmas last year, 14-year-old Anais Fournier went to Valley Mall in Hagerstown, Maryland with some friends. While there she purchased and consumed a 24-ounce can of an energy drink manufactured by the Monster Beverage Corporation. She returned to the mall the next day and consumed another Monster energy drink. Later that […]
Daniel Farber | October 24, 2012
Cross-posted from Legal Planet. Deregulation is one of Mitt Romney’s five steps in his plan to add jobs. But how do we supposedly know that deregulation will add jobs? It’s a fascinating story, featuring a Nobel laureate’s economic model. The model is very fancy, lots of complex math, but it’s justified on the basis of […]
Ben Somberg | October 19, 2012
Here’s a final compilation of our posts on the Clean Water Act at 40: William Andreen: The Clean Water Act at 40: Finishing a Task Well Begun Dan Tarlock: Forty Years Later, Time to Turn in the CWA Clunker for Something Suited for the 21st Century Robin Kundis Craig: The Clean Water Act at 40: […]
Michael Patoka | October 18, 2012
CPR President Rena Steinzor and Member Scholar Thomas McGarity sent a letter this morning to Paul Verkuil, Chairman of the Administrative Conference of the United States (ACUS), taking the independent federal agency to task for its increasingly apparent bias toward the views of industry groups and its troubling alliance with current and former officials at […]
Aimee Simpson | October 18, 2012
Last week I visited a dairy farm with my two year-old son. Complete with hayrides, homemade ice cream, cows mooing, and a bluegrass band, the fall festival provided us with some good, wholesome entertainment. My son giggled as the baby cows licked his hand, oohed and awed at the fluffy baby chicks, and, of course, […]