By Center for Regulatory Effectiveness, Special for USDR
The Center for Regulatory Effectiveness states that EPA’s new “preliminary” ecological risk assessment relies on computer models to predict environmental effects from use of the herbicide atrazine. These predictions are not true. There are no real world data showing that EPA’s predicted effects have actually occurred despite atrazine’s widespread international 12use for over 60 years.
EPA has no real-world evidence showing that atrazine causes real-world harm because, after all these years of atrazine use, there is no harm.
EPA’s unsupported accusations violate EPA’s own Model Quality Guidelines, which require that model predictions be demonstrated consistent with real world data before they are used to regulate.
EPA developed its Model Quality Guidelines after consultation with the National Academy of Sciences on how regulatory models should be developed and used. The NAS Report emphasizes that model results must match real world data before the models can be used to regulate.
EPA’s new risk assessment does not match and is inconsistent with the real world of atrazine use. The harm it predicts does not exist. Its predictions are not accurate and reliable.
Consequently, this risk assessment violates and is subject to corrective action under EPA’s Data Quality Act Guidelines, which require accuracy and reliability.
The NAS Report repeatedly emphasizes that EPA’s models must meet the DQA Guidelines, and are subject to private party correction actions if they do not.
EPA is also subject to private party actions to enforce the DQA’s pre-dissemination review requirements. EPA’s DQA Guidelines require that EPA assure the accuracy and reliability of information EPA disseminates before EPA disseminates it.
The aforementioned violations of established administrative procedures demonstrate that the atrazine ecological assessment is not ready for prime time.
SOURCE Center for Regulatory Effectiveness