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From September 14-17, EPA held an unprecedented fourth Scientific Advisory Panel (SAP) on one product in under a year as part of EPA’s broad ranging, re-review of atrazine.  SAP meetings are resource-intensive undertakings and EPA generally convenes only 8 to 10 such meetings a year for all pesticides in the U.S.  This year it devoted a third of these meetings to atrazine under a timeline too compressed to adequately consider the voluminous data involved.  Unlike most SAPs, which are narrowly focused and address a single discipline, EPA asked the Panels convened on atrazine to address multiple, unrelated scientific topics in a single session.  

The most recent Panel was no exception: EPA asked the Panel to address more than 10 complex scientific topics in only four days.  This compressed schedule is particularly atypical given that, to adequately consider each of these complex topics, scientists and regulators must take into account the most extensive database in existence for a single pesticide (over 6,000 atrazine studies in EPA files).

More relevant was new scientific evidence presented to the SAP by one of the manufacturers of atrazine, Syngenta, which examined doses of atrazine exposure on test animals that were tens of thousands of times higher than the current EPA water standards for atrazine. These doses were delivered at levels far above what any person could conceivably be exposed to in the real world. But even at these extreme doses, atrazine had no harmful effects.

Leaders of the Triazine Network also presented evidence from University of Chicago economist Don Coursey that regulations or lawsuits that could pull atrazine from the shelf would cost up to 48,000 jobs.  EPA itself estimated that the loss of atrazine would result in the annual loss of $2 billion to growers.

EPA continues to rush the re-review of atrazine:
•         Panelists and the public were given reams of information with little time for review.  Less than 14 business days before the SAP convened, EPA released a 677-page whitepaper, which was then followed by EPA’s issuance of 17 questions requesting the Panelists’ comment on a diverse range of complex scientific topics.
•         During the SAP, EPA acknowledged that additional data relevant to its re-review will be available from new studies now underway, but indicated that the Agency would make decisions in 2011 regardless of whether new, relevant information has been adequately reviewed. There is nothing that would suggest such a rushed decision is necessary.
•         Ironically, both EPA and the SAP acknowledged the limited regulatory value of the publications that EPA cited as the basis for launching its re-review last October.  EPA should have considered the adequacy of the studies prior to launching the re-review in the first place.
•         Panelists acknowledged the value of the extensive existing atrazine water monitoring program, including the frequency of monitoring in the current program; several panelists also commented on the value of continuing to focus on finished drinking water (consistent with the law) rather than regulating atrazine exposure by monitoring raw water which is not consumed.

Scientific questions exist about whether some of the data EPA indicated it may rely upon are of sufficient rigor for use in making regulatory decisions, let alone whether the data support a change in atrazine regulation.  Given these critical questions of science, it is particularly important that EPA not rush to conclusions before fully taking into account the extensive database of information that exists and also additional, highly-relevant data that will soon be available.  Reliability, reproducibility and scientific rigor are key characteristics of sound, science-based decision-making and are essential to the current EPA atrazine re-review.

EPA should not be focused on an arbitrary 2011 timeline for making a regulatory decision about the future of a critically important agricultural product.  Instead, EPA needs to continue regulating atrazine using rigorous science, not political expediency.