just for test for a test for test we are waiting for republicans to begin they're always there when you don't need  afternoon the hearing will now come to order welcome today's hearing entitled fixing the integrated risk information system a little more than a year ago susan dudley then the head of the our staff today released a report on iris that shows that awara did just that on several occasions enough to conclude that intruding on scientific assessment was routine for our doubly test by the streamlined process conduct in requiring a perpetual paralysis in approval procedures and intruding on the independence of appears to have been intended to keep ours from doing its job and to keep us all of the dark about the public health consequences of chemical exposure nine illustrate the new process if we are to believe our own as the new process is substantially streamlined just as important discussions between federal government agencies about iris listings will be transparent there is no potential health effects of chemical exposures even as various government agencies on the chemical very useful no agency can trigger an even more tortured approval process by declaring that a chemical is mission critical under strict rules of grammar the word perpetual is like the word naked or nude neither allows for degree by the iris approval process devised by the perpetual for all chemicals and more perpetual for mission critical chemicals we are interested in hearing today about the new procedures and there should be little doubt that the procedures are an improvement but we need to see how the procedures work in practice to know whether the procedures are enough of an improvement the institutional interest ambitions of federal agencies survive presidential trans transitions there will still be agencies who want to use chemicals without annoying restrictions and may try to avoid risk management issues by structuring the risk assessment of an iris listing and it is human nature to forsake power reluctantly even the un wholesome even sinister power that allow or exercise over scientific assessments the american people need and deserve a credible scientifically sound assessment of the health effects of chemical exposure that means the e p a must be in charge not aware of the subcommittee will continue to work risk information system our process was originally developed in the mid one nine hundred eighty s for a specific task different offices throughout the day were relying on different assessments of the health effects of exposure to chemicals iris was intended to establish a uniform database within that representative consensus determinations over time her hours became an authority of resource on chemical toxicity as a credit to the agency's diligence of the agency states and the international community and in these increasing increasingly began to roll out and iris in the cessna took on increased importance these outside groups have sought to impact a process that was not initially designed to handle external pressures the result has been an iris process that has effectively broken down as we learned in jail last year e p a had a backlog of seventy ongoing assessments and managed to complete only two assessments in each of the last two face today the completely on satisfactory time frames for these estimates of the results of several factors reviews are becoming more complex as attention increases for high profile chemicals e p a management and program decisions are delaying completion outside stakeholder reviews are becoming more detailed and congressional action is becoming more prevalent all of these delays to have compound effects and create a domino effect on schedules as m pointed out in previous testimony until recently the hours process was an uptake process that had no schedule deadlines and limited outside review while a previous administration's proposed process wasn't perfect it was the first time that the process was formalized thoroughly examined and given strict timelines if nothing else the previous administration recognized the untenable nature of the existing powers process and presented a proposal to fix the problem by the previous process wasn't perfect neither is this new process previous process is required to pay a developed up consensus assessment the original purpose of the iris process the newly proposed process does not require office to concur on assessments but rather to simply consult furthermore these internal agency consultations are not required to be available to the public which ultimately limits transparency e p a s value to develop assessments raises the questions of how thorough and useful iris will be in the future one of the saddest arguments for the new proposal is its new streamlined process as i mentioned earlier the natural tension between timeliness begs the question of whether streamlined process will ultimately sacrifice scientific credibility especially considering recent negative reviews from the national academy of sciences in order to streamline the process the new administration has cut out quality control measures such as visibility in the adjudication of peer review comments the requirement for qualitative assessment reviews the public review of that qualitative assessment the valuation of agency interesting clip closing data gaps for mission critical chemicals design and implementation of news studies for mission critical chemicals and the development of short term research projects that may aid in filling get data gaps more importantly this new streamlined process uses a bit of sleight of hand to take the scientific literature to review and data calling periods off the schedule entirely this work will still be done it doesn't account for this time in its schedule allowing them to create the appearance of a speedier process one of the largest criticisms of the previous proposal was the role play played by the white house and more importantly o m b and the office regulatory information affairs despite these previous criticisms the new process states that white house offices will continue to be involved in the interagency consultation process apparently this was only concerned when it was politically fashionable if anyone had problem with the previous administration's meddling you can probably expect more of the same says or it is staffed almost exclusively by career civil servants so i try to dismiss this concern by noting the n d p is now alternately responsible for the process but they always have final authority even under the previous process it could be claimed that even with that previous authority a was still subordinate to them lots of o e m be similar one could argue that e p a will truly have final authority on the new process but ultimately the most right to still work for the present the only difference is that now maybe the ministry it also works for the new environment is our carol browner we aren't really sure about this since she is removed from any type of congressional oversight transparency or accountability i hope the science is ripe for place doesn't turn out to be behind the cloak of deliberative process and executive communication despite concerns about white house meddling o m b has provided useful input in additionally o m b plays an important role in the shepparton the interagency process without only be taking the lead in this process it remains to be seen if e p a will have enough clout to force to compel other agencies to comply with its time lines and directions this also raises another question relating to who will ultimately be the juda case of conflicts and arbiter of scientific disputes in an ideal world neither the white house nor e p a would be involved in this as it is truly a discussion meant for the scientific community unfortunately the real world and they need to be a bureaucrat referee is e p a truly an unbiased partner when there they are the agency that draft this estimate what incentive does e p a have to incorporate peer reviewers comments that may contradict their opinions are we setting up a system where e p a will be responsible for monitoring his own work even if  far the office of research and development staff tasked to conduct these assessment experts on every chemical are aware of all the science if the answer is no then aren't we essentially making pure but poorly assessments if none of these questions matter because assessments go through peer review why would it matter if other industry all the white house were involved since the final product will be peer reviewed and you can tailor made very skeptical of the new process but i do see some commendable aspects new transparency measures for the agency review process promising even though they don't extend into internal communication between e p a land office which could prove to be just as informative and important despite this potential bright spot several of the questions remain with that mr chairman i'm attaching a letter from talks toxicology excellence for risk assessment tara t back he is the director of natural resources and environment at the government accountability office our witnesses should know you will each have five minutes for your spoken testimony your written testimony will be included in the record  when you all have completed your spoken testimony we will begin with questions each member will have five minutes to question the panel it is a practice of this subcommittee to receive testimony under oath  although we have not made it our habit to refer cases for perjury prosecution which i'm sure is a great relief dr gray and as dudley you also have the right to be represented by counsel do any of you have any encyclopedic knowledge of this topic you may have other staff with you who may need to you might need to help with a with an answer would be helpful if anybody else from your staff who might i'm dr kevin tyson the deputy assistant ministre for science in e p a s office of research and development i'm also the acting e p a science adviser and in this role i serve as a member of the office of science and technology policies task force and scientific integrity i appreciate this opportunity to discuss with you e p a s integrated risk information system iris before i begin i would like to thank congress in the subcommittee for your support of the program the importance of a successful iris program to the health of the american people was acknowledged by subcommittee and to pass hearings by chairman miller's previous introduction of legislation on this topic your continued interest in the future of the program is greatly appreciated irises one of the most important and most public products iris has been a used by environmental and health professionals in state and local governments as well as internationally because of the widespread use of virus risk information it is of utmost importance to the process used to develop this information and the resulting assessments posted on iris for elect the highest possible standards for scientific quality scientific integrity transparency and timeliness administrator jackson coming from careers about in the new jersey department of environmental protection recognizes the critical role that e p a plays in disseminating timely high quality and accessible human risk information on environmental contaminants just four months after coming to the e p a she announced a new iris process that is more responsive to the needs of the agency and its work to effectively and efficiently protect the he of all americans knew iris process is more timely transparent and will ensure the highest level of scientific integrity it will rely on an opportunity for public review and comment followed by a rigorous open and independent external peer review process to guarantee the scientific quality of the iris assessment there are several aspects of the new process i would like to highlight first the new i was process will be entirely managed by the second there is no longer an opportunity for another federal agency to prolong the process by asking that additional research be conducted before an assessment can be produced instead the chemicals that will be assessed far enough in advance so that any interested party could conduct short term studies that could add to the peer reviewed scientific literature third all written comments from other federal agencies and white house offices will become part of the public record opportunities for scientific comment by other federal agencies and white house offices was maintained in the new process because e p a welcomes input from interested experts that may add to the scientific quality of the draft or final assessment also the assessment process has been streamlined to ensure that more new and updated assessments are included on iris while still robust the assessment development process for most chemicals will be shortened to twenty three months speeding the availability of iris assessments there are two steps introduced in a previous process that were retained in the new process first the opportunity for any interested party to provide information to prior to the peer review meeting these listening sessions allow the interested parties to present scientific comments on draft iris assessments during the public comment period before the external peer review period found the listening sessions to be a valuable step in public outreach and participation second changes in the scientific judgments from public comments and peer review will be clearly documented and explained maximizing the transparency of the final product finally to give this new process an added boost the administrator has directed that for fiscal year two thousand and ten resources for the ira's program should be increased and the president's budget request includes an additional five million dollars and ten f t e full time equivalents for the iris program in conclusion remains dedicated to listening and being responsive to the public to independent experts and to scientists and other federal science agencies as it develops human health assessments the ability of e p a s program to succeed has been significantly improved now that some steps have been removed to revive confident that we can continue to provide the critical human health risk information to e p a s program in regions chairman i'm pleased to be here today to discuss our prior findings and recommendations on e p a s iris program as well as the results of our preliminary view of e p a s most recently announced cyrus reforms announced on may twenty first two thousand and nine as you know the iris database contains e p a scientific position on the potential human health effects of exposure to the more than five hundred forty chemicals in the environment it is a critical component of e p a s capacities to support scientifically sound management decisions policies and regulations in march two thousand and eight we reported that the iris program was at serious risk of becoming obsolete because the agency had not been able to complete timely credible chemical assessments or decrease its backlog of seventy ongoing assessments e p a completed only five assessments last year and as a white completed one assessment so far this year we also found that the time frames for completing assessments were unacceptable the long  taking over a decade and many cases assessments became obsolete before they could be finalized and we're stuck in an endless loop of assessment and reassessment in april two thousand and eight e p a and baled area vies process and we were disappointed to find out that it was not responsive to our recommendations and was actually worse than the process that it replaced institutionalizing a process that would take six to eight years at best to complete enabling federal agencies to delay ongoing assessment by requesting additional research and declaring comments from other agencies deliberative and excluded from the public record as we testified before subcommittee last year we were extremely concerned about the consequences of these problems because iris assessments are after all the cornerstone of scientific integrity happy agency in fact we added e p a s toxic chemical assessment and coal control processes to our january two thousand and nine report on government wide high risk areas in need of increased attention by executive agencies and the congress a designation reserved for only the most serious federal government problems today i am pleased to report that while it is too soon to offer a blanket endorsement the new iris process introduced by e p a on may twenty first of this year appears to be a giant step in the right direction in particular we believe that the new iris process if managed effectively will be largely responsive to the recommendations we made in our march two thousand and eight report first the process will be managed by e p a rather than o m b as the former process was second it addresses key transparency concerns by expressly requiring that all written comments provided by other federal agencies on draft iris assessments be part of the public record third the new process streamlines the previous one by consolidating and all emanating some steps and committing to a two year completion timeframe importantly it eliminates the step under which other federal agencies could have our assessments suspended indefinitely to conduct additional research we also believe that the requested increase of five million dollars and ten additional staff positions will help ensure that more resources are allocated to iris program to meet user needs while these changes reflect a significant improvement that can help e p a restore the integrity and productivity of the program we offer the following observations for e p a to consider as it implements the new process first there are no time frame stated for the literature search and data call in kind of the pre step one this tends to understate the twenty three month timeframe for completing assessments second it's not clear what  purpose what the purpose of the interagency consultation meetings is which is step three and step six be the new process what the role of all and be another white house offices are exactly and whether decisions will be documented in the public from decisions coming out of steps third it seems to us that comments from the federal agencies which is step three could be solicited sametime draft assessments are sent to independent peer reviewers and the public which is step four and saving additional time in the process fourth it's not clear how e p a plans to respond to our march two thousand and eight report recommendation to provide at least a two year notice of planned assessments the new process does not specifically address such important planning steps as the call for nominations of chemicals to be assessed and the establishment of an iris agenda we believe that giving agencies and the public more advance notice to plan assessments would enable x turn all parties with an interest in a given chemical to complete relevant research before the start of an iris assessment and thus make the assessment even more efficient finally unlike a number of other e p a programs with statutory deadlines for completing various activities no enforceable deadlines applied to the irish program we believe that control was very much eroded by pressures from other agencies that although the iris listing has no regulatory effect it is a precursor to regulation and there were agencies assessment and not have to worry about it and there were officials at o m b who seemed to be more than happy to help them in that effort but at zero hour whether it was the other agencies or the manufacturers of the chemicals or simply an anti regulatory  in effect be in control even though it may according to the stated procedures be in control a multi faceted question oh and b does serve a purpose in facilitating inner agency comments there's no question the problem with the old process was that all of those comments were declared deliberative and so there was no honest broker if you will as to what comments were being provided and when so we think the fact that this process allows for  complete transparency and all of those comments which is supposed to be comments on the scientific integrity of the assessment be made public so that's huge having said that you know e p a like every other agency works for the white house and o m b as an office of the white house and so the proof is going to be in the putting as to how much influence o m b may or may not have in this current process now with you asking us to do so we are going to be watching that closely are there things for us to watch for there could be early indicators that will tell us that the e p a is truly in charge or only nominally in charge and still being run out of  about the by the white house what the only thing you can really do is track individual assessments through the process and see what kind of comments are made and by whom and what the reaction is to those comments interesting and the old i o n b while it's true they said that e p a was in charge if you talk to ira if you talk to the other part of o m b they would clear up to did the park reviews if you're familiar with those they cleared they clearly said that o m b was in charge so even with a no and b it was unclear who was in charge of that hire us process or mr stevens and the opening statements kind of raised the question of whether there should be more process more procedures more of a chance to challenge e p a that it should not be the final  r should not make the final decision on whether on ars listings but the iris listings have any regulatory effect is there anything that anybody cannot do or has to do because  the way of chemicals listed in iris you know you correctly mentioned that it is a precursor to deciding how to control dangerous chemicals if you need to at all and so we view it as a purely scientific process that shouldn't be metal and shouldn't be next with scientific policy which also has a legitimate role if there is a regulatory effort after the after and hours listening  well sure i mean you have an opportunity to to question the relevance of this science for a given regulation but each one is i case by case issue the beauty of virus is that it is the official agency position on a given can make a law and therefore the starting point to decide where you want to go from there doesn't mean anything about regulation purely with the found formaldehyde industry for instance want to argue that formaldehyde is actually good for you they could do that in outside stakeholders play if they have remember iris is supposed to be a collection and a cent that's existed in research that's available at the time the assessment is it begins essentially and so  there are good researchers and scientists throughout industry throughout the other federal agencies throughout akademi and all those people are allowed to contribute to an individual assessment once they see the draft assessment and it goes out for public comment and all of those comments can be seen by the public and that it by other scientists and everyone in this process seemingly can see how e p a dispenses with each of us comments chairman miller referred to me as dr brown i'm a physician there are some on this whole committee that would argue that i'm not a scientist but i am sure some research scientists that would argue that but i'm an applied scientist and i believe in the scientific process and believe  and lots of it the more peer reviewed enters in the process the the greater i think we have in scientific integrity when i graduated from medical school things i was been taught at that time to be absolutely factual have subsequently been shown to not be factual and i think we have a lot of things going on in public policy today such as climate change caused by human  transparency but is all the discussion within the agency within anybody who has comments on the on the substance being done is all of that available for public purview and it's supposed to be everything we hope to sell like you say it's a scientific process and we would hope all of that is very public and that it in the public about all arguments interagency or arguments any consultation meetings things like that well all of those things be available for public part of you we don't know but that's why we say more clarification is needed and consultation steps within the process and if there are any decisions made our recommendation would be that they may be made public but e p a may have a better clarification on that is certainly our intention to make sure that all of the written comments are put in the public docket but we also know that there are sometimes discussions that go on and orally we would hope in those discussions and what we've tried to do since will be controlling the process to encourage people to provide the porton points even in those oral discussions in writing so they are made open and transparent to the public everything that's just within the inner agency discussion steps at three step three and step six  chart number three mr chairman if i remember correctly i think it's also important to note that when there are disagreements potentially between agencies which can occur that that's when it's a good time in fact to turn to peer review just as you've identified and so it's the consultations both inside the agency where we may have some scientific disagreement on a draft assessment as well as when we have the interagency discussions that those become in fact very good charge questions to the peer review panel for them to a pioneer on to inform us in the federal system well i hope that you can assure the committees it that all opinions particularly dissenting views within any or all discussion of consultation is available for for public purview because i think it's absolutely critical for for scientific integrity first thing secondly is to it is certainly something as i think mr stevenson has mentioned that is a bit vague in the process as a den of phaidon something that requires further discussion and clarification to be more precise so i would prefer to have that discussion before i assure this committee at this particular time but it is something we will certainly have discussion about if i may for just a brief moment however i want to make sure we are distinguishing sometimes between those comments that are scientific in nature and those that may be policy in nature because it is indeed we hope with our iris process to really focus on the scientific comments because indeed their iris assessments are not regulatory and if i may draw attention actually to a report by the bipartisan policy center that you may be familiar with since it's co chaired by share with boehlert a friend i believe of this committee in the past and has this team members on it such as lynn goldman and john graham from there for across the political spectrum i think the screen is actually obscuring the portrait of mr boehler but anyway i did want to make it clear that indeed your comments about scientific disagreements we certainly want to make sure but we want to distinguish those from policy ramifications these are the recommendations in fact from chairman boehlert bipartisan committee distinguishing between science and policy is not always easy or straightforward and scientists must make choices based on values in the course of their work nonetheless policy debate would be clarified in enhanced if a systematic systematic e were made to distinguish between questions that can be resolved through scientific judgments and those involve judgments about values and other matters of policy so we're trying to here is to keep the focus on the scientific arguments that are the basis for the conclusions drawn a and it is later in subsequent steps when regulation occurs that the policy ramifications can be debated as well thank you dr my time is longer than the chairman a very very long suffering but i just want to make one statement from a chair and policy makes a difference too and in these to be transparent and we need to make absolutely certain that any discussion of policy or scientific i think is available for the public like mr chairman thank you schedule i believe but how are you going to make sure that these dates are met with a different process we're going to do our absolute best in terms of a guarantee i cannot promise that every assessment will last only twenty three months there will indeed be situations and we hope they are few and far between and indeed this is stated in the administrators testimony as well that she gave two days ago on the other side of the hill if you will that in most assessments we expect to try and stick to the twenty three months  i've worked for the administrator now for five months i can tell you she is a very intelligent very aggressive individual who will keep us on our toes and do everything she can to support our efforts in that regard you also should hopefully take some solace in the fact that the policy was discussed i was certainly not in the room as it was but among the administrator and her staff half and officials within be and i don't know other agencies perhaps too and there was agreement across the board on this particular process so i believe there will be other agencies who will be held to task as we try and hold to the schedule the commitments that they made to the administrator in those initial negotiations and this just isn't do any comments on this in terms of how you think this could be achieved we've already mentioned that some of the early steps are missing so you're already behind the eight ball in the twenty three months most importantly it's mentioned on the chart here that you're going to do a comprehensive laser surgeon dat that everybody the whole research community well in advance will know which chemicals are going to be assessed two years down the road and can put together any research they deem appropriate before the process actually starts that clarifications but if yes some are clarifications and some i wrote written down i'm not sure i've got them all correctly written but i will state that as hopefully and i think i can if i parrot back correctly the statement of co witness here that if managed effectively the new e p a process for iris would be considered very responsive to the g a o recommendations of the passed therefore we are trying to demonstrate a commitment to seriously consider which tells us and we will consider the recommendations that the co witnesses asked we would like to have a chance to try the process as it's been agreed to and i think mr stevenson has said it's worth a try but we need to take a look and see how we progress i know that the chairman has asked g a o in a year to report back and i think we're anxious to follow that particular path but we will still nonetheless consider certainly for clarification the recommendations and even some of the potential twenty minutes half an hour and i intentionally just have questions probably until that time and then that will be the end of our hearing when we get called for four votes dockside from there were questions about written everything written is going to be available there's no assertion that it's deliberative we all get to see it congress sees that the american people sees that it's public dr around ask questions about oral discussions telephone conversations in the past when we have asked specifically dudley about who was involved in what conversations and what what conversations there were and and what was said she asserted a only reason that congress or a court is asking for it is out of otto curiosity but if there's any real need for it all it should be available is my understanding is the administration does not now does not assert a deliberative process privilege for any or all come conversations so if congress calls upon people involved in decision to tell us who was in the discussion what they had to say that that would be something those would be so we need to wait and see proof that the problems that we've observed have been addressed and there's no you know it's it's it's not it's fairly subjective it's up to g a o when we decide  add or remove things from that risk it doesn't carry any designation other than the fact that we hope that the agency and the administration will devote greater attention to it and the congress for that matter that's why we do it so to get on that list we're very very very concerned where a conservative agency and it doesn't get put on that list there are only three new additions to the list this year and this was one of them dr taj not saying it's a high priority to get off that list and most certainly sir thank you the status of that and we haven't done any specific work on that it was one of the chemicals we highlighted to illustrate how broken the process was and how long it was taking i believe it had been an assessment over a decade and updating for this hearing we noticed that it had been removed from the list of chemicals undergoing assessment where haven't been able to follow up on to exactly why that that happened it was on there a month ago and removed as of a day d x has gone missing i can tell you what response i got when i posed that same question to the staff nonetheless i would prefer to give a fuller response is a question for the record where the chemical managers involved would be able to comment on the decision process that is involved that particular chemical but it was in the list of possible assessment under the ira's program we've identified forty eight assessments that we think are priority chemicals and in the second batch an additional forty eight r d x is in the second batch so i would prefer again for the question for the record to give the decision process as to why it's in the second batch if you would rather record the question is will this streamline process ultimately sacrifice scientific credibility especially considering recent negative reviews of the by the national  question i have really for both of you is a if a can't get the cessnock right ten years what makes you think each one of you that you can produce better results in twenty three months  i mean we're going to we think twenty three months is optimistic we're going to be looking but the problem is it's like a domino effect that's the assessment takes too long there's new research that comes available you have to reconsider and it goes back to square one again that's what i meant about the analyst assessment and reassessment this is supposed to be a process that sent the sizes existing research that's available at the time and should be able to be done fairly quickly  these assessments are supposed to be updated routinely you know every ten years so with five hundred fifty forty chemicals in the last if you're not doing at least fifty four a year you're not even keeping up so we think this is very ambitious we're not sure there's enough resources devoted to this yet but that's a very good question it is an ambitious goal i don't disagree and we have asked for additional resources to help us meet that goal in the president's budget request there are a couple things i think though that are different than perhaps the past as we look at the new process the first is this new process as i mentioned earlier was developed in consultation with other federal agencies and therefore i believe there is a mutual commitment to try and meet the schedule that it's been today fight this does not mean that it isn't aggressive in that we shouldn't take a look and see in a year's time that we've been able to stick to it we welcome that type of review and hope to be able to successfully demonstrate we were able to meet that goal of twenty three months a second is the listening sessions that i referred to earlier are still maintained in this process this is a chance where at the external peer review meeting but where there used to be an opportunity for somebody to speak for two or three minutes or perhaps as many as five or seven minutes no longer than i was able to testify today i would add most likely that that was perhaps insufficient time for real discussion and exchange the listening sessions actually now are for much longer periods of time more interchange with those who have any opinions they wish about our draft assessments and that listening session is indeed also shared with the extra noby review panel and their assessment so i believe that's a very positive step that will hopefully enable us to share for greater longer periods of time potential disagreements in the scientific facts and let the external peer review panel tell us their disposition on those arguments as a time frame for peer review change to the i believe the time period and i'm not really interested and a lot of conversations i go on around the water but those those conversations that do have to do with taking fake integrity as well as a scientific process i think a very important hope that we can as a committee can be reassured that those conversations will be reported in will be open and public view and it's just something i think   it can be done through an academy of sciences study can you give us a sense of what each of those different methods for peer review will cost and how you would decide which method first of all let me since i was under oath correct the statement i said before about sixty days witnesses said it now that i have it in front of me it is one hundred five i was confusing with a different step in terms of the cost of the individual types of peer reviews i would like to provide that is information for the record however it is important to state that we very carefully consider the complexity of the given the cessna as to which form of peer review that we would use to use a letter if you want an iris assessment would be very rare at the other end of the spectrum to go to the national academy of sciences which we have done on the most controversial of chemicals is hopefully equally rare more times than not it will convene a peer review panel which would have a face to face meeting that might be  contractor the panelists or it might be our own science advisory board and the costs of those four different options will be glad to provide but certainly they vary as from the letter of you to the n a s based on the complexity of the assessment can you can you tell us who some of the contractors are who's been contracted with u b s contracted with conduct the peer review i'm only familiar with one and any mention is not considered an endorsement but nonetheless i think the eastern research group has been one of the organizations that our national center for environmental assessment has used to locate peer reviewers and pull together such panels what procedures do you have in place to make sure that there are no conflicts of interest with  firms conducting the peer review process the firms themselves again i would prefer to have a better chance to put this in the records and i'll be able to convey right now but if you're talking about the choice of the firms those are competed and i don't know what confidentiality or impartiality statements they may have to be to be successful better on the contract however the people who they hire as sub contractors as panelists there there are indeed  statements that have to be provided where people state with their potential associations are and they demonstrate that they are impartial mr stevens and are you familiar with any work done on the outside contractors not specifically contractors but there are still two different brands of scientific advisory committee said he uses there's twenty four of them in total and we noted in the testimony in the senate that seven of those have specific conflict of interest procedures for their membership but the others do not and they are there that may not be inappropriate because you are trying to seek points of view on a given chemical  given scientific assessment or a given regulation so we just observed that that e p a should not confuse the purpose of both of those two different kinds of scientific advisory committees dr tyson it seems that some of the most toxin how are you going to set priorities for completing assessments well indeed we wish to tackle those chemicals that we think pose the greatest risk to the american public and those become our priorities that is not an issue of any particular stakeholder group interests one way or the other anybody influencing our decision other than we believe it poses a high risk in those become the chemicals that we go after and we believe we do it in a rigorous fashion that everybody has an opportunity to comment and to tell us if we've gotten it right now a draft and hopefully we done a correctly by the time we have the final assessment ok are you going to include others both interagency suggestions or outside we take suggestions from everybody as we publish our list of potential chemicals we could be working on and others that people wish to recommend and that includes other federal agencies it includes state and health organizations it's a f r a federal register notice asking for people's thoughts on what our agenda should be a year back the remaining three peer review and and again as a physician i'm concerned that sixty days one hundred five days may or may not be enough and twenty three months may not be enough time to adequately evaluate each of these chemicals how can you guarantee that in the review process how can you guarantee fairness in our process if you give the public only sixty days to review believe sixty days will be adequate adequate to give the public fair opportunity to comment we believe the combination of the listening sessions gives them even a chance to interact with us on the draft assessment prior to the extra no peer review panel coming together  if indeed somebody in a rare instance asked for an extension and indeed the material in front of you discusses that potentiality we do indeed offer such an extension but we can't promise in fact that their comments will be before the review committee and we believe it's best for as many public comments to be shared with the peer review committee as they make their deliberations was a sixty day number just pick a somewhat arbitrary yell just think that that's a good period of time or was there a particular fault in in given enough time but not too much i think that's a fair way of putting it it was not arbitrary in terms of but that are randomly plucked out of midair we think this is an appropriate amount of time if it turns out as we have explored this that people feel they must have ninety days for example it is something to consider down the road  materials but which is decides will not it will not allow to make its assessment decisions yes indeed all comments that we receive in a written form as we've discussed will be in the public docket and we always include all the information that has been given to us whether or not it is what we use in our final assessment so that people see the total record and they can choose from among it is what they think should be influencing our final word so that's a promise that will be done  hope you can promise us at some point that all those old discussions and those conversations and consultations that are carly will be will be provided for the public also ever not put every written comment that we got from the public or as part of the peer review in the docket what is interesting and new in this process is in fact now the written comments we get from the inner agencies will also be in the public  you've taken ours to raising that we're having this hearing and it's your continuing this process because i think it's absolutely critical for the public to have total confidence in what assessments are made by r s and by the government across the board i think there are many things that are being put out by the government that are declared scientific that aren't and does not things in the way of determination weeks for additional statements from the members and answers to any follow up questions that committee may have the witnesses dr types when you said you want to provide additional information in without the witnesses or excuse in the hearing is now