RE: raw data

[Jim Cooper <james.cooper@socma.com>]

Rich,

The HPV Challenge is a voluntary effort.  There is no EPA rule
telling industry that they have to test the 2,000 chemicals.
Industry is doing this on a voluntary basis.  This can be verified
through the HPV Branch at EPA's Office of Pollution Prevention and
Toxics.

EPA toxicoligists use structural-activity relationships every day
in their jobs.  Yes, I agree more information, especially in the
areas of developmental and reproductive toxicity, is needed.
However, I do believe that the information "vacuum" is greatly
exaggerated.

As for the study results reported to the TSCA Docket under Section
8(e), the overwhelming majority follow what are called Good Laboratory
Practices (GLP), which are guidelines developed by EPA to ensure
the quality of data.  These same procedures are used by toxicologists
in labs around the world, in academia, government, and industry.
Yes, there certainly are submissions entered confidentially.  In
the commercial field of chemistry, which is one of the most
competitive in the world, business relationships and the chemicals
involved in them are very vulnerable.  A company can literally lose
an entire line of business, which is crucial to their survival, if
a competitor finds out what chemical compound they are making, and
for what purpose.  The toxicity data under confidental submissions
do not hide what the adverse affect is, it just protects some of
the details so that companies can stay in business.

Sincerely, Jim Cooper