Information Quality Guidelines Staff Information Oualitv Act Request for Correction

Dear Sir or Madam: This request for the correction of information is submitted on behalf of the Wood Preservative Science Council (WPSC), under the Information Quality Actl and the implementing guidelines issued, respectively, by the Office of Management and Budget (OMB)2and the U.S. Environmental Protection Agency (EPA).3 The WPSC is a trade association of manufacturers of water borne wood preservatives, including chromated copper arsenate (CCA). It supports and participates in objective, scientific analysis of water borne wood preservatives with a focus on CCA. The WPSC consults with the nation's leading experts in the fields of environmental science, epidemiology, risk assessment, and toxicology. EPA's Guidelines expressly contemplate the correction of information disseminated by EPA that falls short of the "basic standard of quality, including objectivity, utility, and integrity," enunciated in its own Guidelines or those issued by OMB. ("Issue Paper"). These documents are indisputably "influential scientific.. . infonnation," which under the EPA Guidelines is subject to "a higher degree of quality." The EPA Guidelines define "influential" infonnation as meaning that "the Agency can reasonably determine that dissemination of the infonnation will have or does have a clear and substantial impact (i.e., potential change or effect) on important public policies or private sector decisions." EPA Guidelines at 19. On July 24,2005, EPA asked the Science Advisory Board (SAB) Arsenic Review Panel to review these documents in assessing the cancer risks associated with oral exposure to inorganic arsenic. The Panel's report will be used to infonn EPA's decision-making regarding arsenic, including the drinking water standard for arsenic and registration decisions for arsenical pesticides such as CCA. It is also clear that this material has been disseminated. In addition to being submitted to the Arsenic Review Panel, the documents have been posted on EPA's website.4 I. Peer-Review EPA has stressed the importance of peer review for scientific documents.5 Yet neither document appears to have been peer-reviewed. There is a statement regarding peer review on page vi of the IRIS document, but there are no peer reviewer comments included in Appendix A. It therefore appears the language on page vi is merely a placeholder, and that this document has been disseminated prior to such review. EPA has a responsibility to make the peer-review status of these documents transparent to the reader. We understand these documents are being reviewed by the Arsenic Review Panel, but the documents also should be subject to fonnal, external peer review …