Currently studies conducted to satisfy the guideline requirements for toxicity testing of pesticides are copied over by contractors at taxpayers expense. This practice is wasteful and does not give added value to the study. The Agency should design formats for the submission of these studies that the testing laboratory completes to include the critical information for the reviewers to judge the study for its quality and intertretation for regulatory purposes. The quality of the study is set in the design, conduction and reporting at and by the laboratory. The reviewers cannot change the quality but can judge it and idnetify the toxicologically significant effects of the pesticide. The formats would be submitted together with the complete study report and the reviewers would verify the content of the formats against the full study report and indicate study deficieincies. Submitting these formats will save the Agency both time and resources to the benefit of the taxpayers and decrease the review time to benefit the registrants. The integrity of the review process would not be compromised.
Idea No. 15393