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How Many Times Do I Have To Tell You?! Epa's Ongoing Struggle With Data From Third-Party Pesticide Toxicity Studies Using Human Subjects, Heidi Gorovitz Robertson
How Many Times Do I Have To Tell You?! Epa's Ongoing Struggle With Data From Third-Party Pesticide Toxicity Studies Using Human Subjects, Heidi Gorovitz Robertson
Law Faculty Articles and Essays
This article addresses EPA's current and historic policy struggle regarding the position the Agency should take with respect to pesticide toxicity studies done by third parties in their attempts to register pesticides. Chemical companies often conduct these studies, or seek third-parties to do so, and submit the results to EPA in support of applications for pesticide registration. Although EPA had a high level joint Science Advisory Board/FIFRA Science Advisory Panel make recommendations to it on this subject in 1999, last year EPA asked the National Academy of Sciences to conduct additional, almost certainly duplicative review. Specifically, EPA has asked the …
Pesticide Toxicity, Human Subjects, And The Environmental Protection Agency's Dilemma, Heidi Gorovitz Robertson, Samuel Gorovitz
Pesticide Toxicity, Human Subjects, And The Environmental Protection Agency's Dilemma, Heidi Gorovitz Robertson, Samuel Gorovitz
Law Faculty Articles and Essays
Should humans be used as subjects in research designed to determine the toxicity of pesticides? If so, under what conditions should they be used? If not, why not, given that human subject testing is common in research studies designed to determine the safety and efficacy of drugs? Should the EPA seek, or even accept, the results of such research in formulating the evidentiary base it uses in making decisions about pesticide registration? This article does not propose to answer these questions, but to illuminate the process by which they are addressed and offer some suggestions about how other such questions …