Endocrine disruptor screening program: Data sharing, compensation, protection

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Courtesy of Bergeson & Campbell, P.C.

Now that EPA has published its list of the first chemicals to be screened under the EndocrineDisruptor Screening Program, the authors of this article say all technical registrantsof listed active ingredients, and all manufacturers and importers of listed inert ingredients,must begin to prepare for how they will address joint data development, cost sharing, datacompensation, and data protection. The authors compare the program and its policies withthe long-established data compensation provisions of the Federal Insecticide, Fungicide,and Rodenticide Act. They say it is none too soon to start thinking about legal, business,and communication strategies that best address applicable legal obligations, while protectingcommercial and business interests.

The Environmental Protection Agency issued threeimportant Federal Register notices April 15, 2009,laying the foundation for the Endocrine DisruptorScreening Program (EDSP), EPA’s next major data developmentinitiative. This article focuses on those aspectsof EPA’s Federal Register notices concerning howEPA will address joint data development, cost sharing,data compensation, and data protection under theEDSP (EDSP Policy Notice).

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