Note: This information is provided for reference purposes only. Although the information provided here was accurate and current when first created, it is now outdated.

WORKGROUP #1 COMMENTS ON FRAMEWORK FOR REFINING FQPA SCIENCE POLICIES

Comments on the Matrix

• Add definition of reliable data as a 9th issue (what are the data that bear on regulatory decisions and what are the limitations associated with the data sources)
• Develop a bibliography of data, including information on limitations of the sources (e.g., that state water monitoring data are available only for certain states)
• Add 99.9% to the Monte Carlo issue
• Provide a brief summary of the comments/findings referred to (i.e., where the matrix now says SAP considered an issue and provided comments)

Issues

• How to reduce risk strategically (i.e., how to get the most risk reduction in the least time without eliminating the economic benefits of pesticides--can't do it one chemical at a time)
• How to ensure consideration of unintended consequences
• Implications of asking for more data
• Use of data helps make the data reliable, i.e., help find the boundaries for policy and regulatory purposes
• What does/should EPA do when data are lacking?
• How does/should EPA use the published literature?
• How to avoid the trap of never being able to say there are enough data?

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www.epa.gov/pesticides/trac/8_1cmts.htm
updated June 29, 1998