Document vjeke4Zrp3rjJn1p2v0vrmYw

fe 24 rember 28, 19S4 PESTICIDE k TOXIC CHEMICAL NEWS . The agency's draft proposal includes docketing and other public participation provisions which were in the agreement settling the decision conference suit brought against EPA by the Natural Resources Defense Council (See Nov. 21, Page 11). The draft provided for preliminary notifications (private) to registrants and applicants of initiation of special reviews. The registrants would have 30 days "to dispute the validity of the agency's conclusions or to present information in response to the notification." If after issuing the preliminary notice, EPA decides not to start a special review, the agency will explain the proposed decision in a Federal Register notice and ask for comment on it. The draft also provided for "informal public hearings during a special review" to gather relevant information or otherwise assist agency decision-making. It included a provision for the following expedited procedure: "The agency may elect to issue a notice of special review and a notice of preliminary determination simultaneous ly; or, to initiate cancellation, suspension, or denial proceedings concerning the pesticide or any of its uses without first conducting a special review. If the agency elects to issue a simultaneous notice of special review and notice of preliminary determination, the agency will make the docket for that decision available for public inspection no more than three months after private notification of the registrant by the agency of its risk concerns at the initiation of the pre-special review process." C J PA CHOICE OF LINEAR EXTRAPOLATION ATTACKED EPA's choice of the linear mathematical extrapolation model as the method of deter mining carcinogenic risk was criticized by two cancer specialists at a press briefing in Washington Tuesday (Nov. 27) called by the American Industrial Health Council (See Nov. 21, Page 12). Both Dr. Philip Shubik of Oxford University and Dr. Morton L. Mendelsohn of Lawrence Livermore National Laboratory said the agency was wrong in trying to get one number by one specified method for all presumed carcinogens. There "isn't any way to get a (single) model for carcinogens," Shubik said at the AIHCsponsored briefing. That organization had funded a workshop, chaired by Shubik, to assess the criteria for evidence of chemical carcinogenicity. is a member of the panel and also is chairman of the National 's Board of Scientific Counselors, said EPA might have suggested mathematical models currently accepted, rather than specifying hod. ussion of mathematical modeling "built up the logic that no one model superior, and then the agency picked the linear model. The animal sfined range of statistical power, he said, but the "problem is that the >w what happens with very small doses over a lifetime." lear to me that what we want is the most conservative answer," 'In my view, the most cautious answer might be best." #