RE: raw data

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

Rich,

You've hit on what I think is a very relevant point in this thread
exercise:  it is important that all sides of the story be told,
whether in policy or scientific data.  All views should be presented.
No entity, government or otherwise, should be able to control what
is presented, or not presented.  Information should be presented
as the original author intended, whether it is data, comments, or
comments relating to comments.

I'm not claiming that industry toxicologists think they know all
that they need to know about chemicals; quite the opposite.  I
am claiming, however, that the program would be better if
toxicologists had been allowed to design it from the beginning.
I'm also sticking to my point that the "ignorance" factor has
been greatly exaggerated. 

In your argument about the regulatory "hammer" to use as an 
incentive, you're forgetting that EPA has not been historically
successful issuing Section 4 or Section 6 test rules.  They've 
lost these battles on both procedural and scientific grounds.  
The American Chemistry Council (ACC, formerly CMA) worked
with EDF and EPA to design the basic parameters of the program.
Both EDF and ACC (back when it was CMA) asked that the regulatory 
backstop be placed in the program.  EPA does have a proposed Section 4 
test rule under review at the White House Office of Management and 
Budget (OMB), but there are less than 80 chemicals on the rule.  
A test rule covering 80 chemicals does not pose much of a threat
to industry, let alone induce companies to voluntarily sponsor
over 2,000 chemicals. 

Respectfully,
Jim Cooper