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EPA responds to Environmental Working Group

October 27, 2004

United States Ennvironmental Protection Agency
Office of Research & Development
Washington DC 20460

Mr. Kenneth Cook, President
Environmental Working Group
1436 U Street, NW, Suite 100
Washington DC 20009

Dear Mr. Cook:

I am writing in response to your lettert of October 15, 2004, to Administrator Michael Leavitt concerning the Environmental Protection Agency's (EPA) recently announced partnership with the American Chemistry Council (ACC). The Administrator asked me to respond on his behalf, and I am pleased to do so.

In your letter, you question whether the Cooperative Research and Development Agreement (CRADA) will allow the ACC to manipulate the results of EPA's research study. Let me assure you that they will have no such ability. The $2 million from the ACC is $2 million with no strings attached.

EPA is committed to maintaining the highest scientific standards in all of its research programs. This includes the Children's Environmental Research Study, which is an impoirtant study that will allow EPA to understand better children's exposure to pesticides and other chemicals in their home environments.

Because this is such an important research effort, EPA has partnered with the Center for Disease Conrol and the Duval County (Floirida) Health Department. The ACC is providing funding that will enable EPA to expand beyond a pesticides-only study to collect information on selected phthalates, brominated flame retardants and perfluorinated chemicals, which we would otherwise not be able to study. The study itself will be conducted by a qualified team of scientists who do not have ties to the chemical industry.

Before beginning this study, EPA career professionals developed a study design for the pesticides-only study that was independently peer reviewed. We then submited a proposal to the ACC to expand the chemicals monitored. The ACC accepted the proposal without any influence over the study design or the chemicals EPA would select. The study design describes in detail what will be measured, how the data will be collected, how the data will be analyzed, and how the data will be quality assured. By following this study design, EPA will maintain its rigorous standards and ensure the integrity of the study. EPA has also formed a Peer Advisory Committee that will provide technical advice during the course of the study. This committee consists of representatives from both academia and industry. The ACC will not have any ability to manipulate the outcome of the study, and EPA will maintain control over the release and publication of the research results.

EPA believes that partnerships are essential to finding solutions to today's complex environmental problems. We currently have more than 80 active CRADAs with organizations that include universitites, private industry, non-profit organizations, and public utilities. Not only do these CRADAs allow EPA to leverage its research dollars, they also allow EPA to take advantage of the scientificd expertise of the partner organizations.

Your statement that this cooperative research effort with industry sets "an ominous precedent" is just not accurate. Over the past 15 years, EPA has entered into many CRADAs with industry. For example, during the Clinton administration EPA signed research agreements with Chevron, Dow Corning, DuPont, Eastman Chemical, the Petroleum Environmental Research Forum, Proctor & Gamble, and others. In my opinion, the American Chemistry Council should be commended for participating in this CRADA to advance our understanding of how children may be exposed to the chemicals used by its member organizations.

In conclusion, EPA believes that CRADAs, as authorized by Congress in the 1986 Federal Technology Transfer Act (FTTA), are an important means of fostering collaboration between the federal government and the broader scientific community. For your reference, I have enclosed a fact sheet that describes EPA's FTTA program, as well as a list of our active and expired CRADAs.

Sincerely,

Paul Gilman, Ph.D.
Assistant Administrator

Enclosures

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Excerpt from Enclosures:

ACTIVE CRADAs
File Number	Partner Name	Area of Tech Transfer [* - Not Listed]
317-04	Affymetrix, Affymetrix, Inc., Affymetrix, Inc.	Gene chip technology
221-02	Agilent Technologies Inc.	Drinking Water-organotin
269-A-03	Ambient Group Inc.	Black Mold
214-01	American Chemistry Council	Wildlife reproduction
215-02	American Chemistry Council	Immune system
305-04	American Chemistry Council	Children's Health
208-01	American Water Works Research Founcation	Cryptosporidium - UV light
296-04	Arizona Water Company, (Rimrock & Valley Vista)	Arsenic removal
278-03	ASARCO,Inc., ARSARCO, Incorporated	Permeable Reactive Barrier
324-04	AVL Powertrain Engineering	*
166-99	BP Amoco Corporation	Phytoremediation of TPH
216-02	Camp Dresser and McKee	Sanitary Sewer Systems Control Planning
218-02	Camp Dresser and McKee	Stormwater Mgmt Redevelopment
286-03	City Hall of Climax	Arsenic removal
281-03	City of Brown City	Arsenic removal
285-03	City of Fruitland ID	Arsenic removal
283-03	City of Lidgerwood	Arsenic removal
187-00	Composite Membranes Corporation	Pervaporation Membrane-VOCs-wastewater
270-03	Coordinating Research Council Inc. (CRC)	Vehicle exhaust
280-03	Cummins	Clean diesel combustion
243-A-03	Digital Diagnostic Systems, LLC	Black Mold
327-05	Dionex Corporation	*
194-A-01	Eaton Corporation	Hydraulic Hybrid Vehicles
301-03	Eco Array	Fathead Minnow
323-04	Eli Lilly and Company	MTA
203-01	Envirogen, Inc.	MTBE and propane biostimulation
259-A-03	Environmental Laboratory, Inc., Pure Earth Environmental Laboratory	Black Mold
200-01	Environmental Research and Education Foundation (EREF)	Landfill gas emissions and control tech
265-03	Environmental Research Consortium (ERC) (DaimlerChrysledr, Ford Motor Company, GM), Haagen-Smit Lab (CA Air Resources Board -	Vehicle emissions
315-04	EST Analytical	VOCs in soil and water
303-04	Fielding Chemical Technologies, Inc.	MTA
202-01	Fluent, Inc.	Computational Fluid Dynamics Methodology
291-03	Ford Motor Company	Environmental fallout on auto products
162-98	Ford Motor Company	Automotive Power Train
191-00	Foremost Solutions, Inc.	Biomediation-contam soil-GW
253-03	Genetech, Inc., Genetech	MTA
274-03	Genetic ID NA, Inc .	Black Mold
170-99	Genzyme Diagnostics	MTA
258-03	Georgia Pacific Corporation	Air Pollution
264-03	Glaxo-Smith-Kline	MTA
261-03	Hach Company	Homeland Security-Water
263-03	Hybrigene, Inc.	Gene flow-transgenic crops
311-04	INCELL Corporation, LLC	*
326-04	Inficon	*
266-03	Instant Reference Sources, Inc., DOI/USGS, Instant Reference Sources, Inc., U.S. Geological Survey, 8505 Research Way,	Natl Env Methods Index
0293-04	International Truck & Engine Corporation	Clean diesel combustion
181-00	Membrane Technology & Research, Inc. (MTR)	VOC separation-groundwater-wastewater
190-00	Metal Alloy Reclaimers, Inc. (Metaloy)	Ionic Mercury in scrubber water-Spent Claus Catalyst
292-A-04	Microbac	Black Mold
306-04	Monsanto Company	MTA
262-03	Monsanto, Inc.	MTA
173-99	Niagara Mohawk Power Corporation	Phytoremediation of TPH
242-03	Novartis Pharmaceutical Corporation	MTA
257-A-03	Parker-Hannefin Corporation	hydrostatic transmission-large vehicles
178-00	Petroleum Environmental Research Forum	Phytoremediation
201-1	Pfizer Ltd., Global Researchand Development, Pfizer	MTA
171-99	PPG Industries, Inc., Goodyear Tire and Rubber Company	Landfill alternative cover system
272-03	Pure Sense Environmental, PureSense Environmental, Inc.	Homeland Security-Water
284-03	Queen Anne's County, MD	Arsenic removal
276-03	Rollinsford Water & Sewer District	Arsenic removal
207-01	R.J. Lee Group	Microscopy based particle char tech
183-A-00	Schleicher & Schuell (formerly Biopath)	E.coli-coliform bacteria
271-03	Scotts Company	MTA
316-04	Solutia Inc.	MTA
290-03	South Truckee Meadows General Improvement District, NV	Arsenic removal
239-02	Technical Database Services, Inc.	Environmental Toxicity & Exposure DB
220-02	Technology Inc., Inverness Medical Technology, Inc.	Fertility and SP-22
179-00	The Research Foundation of State University of NY (SUNY)	MTA
282-A-03	Tipton Environmental International	Biomass Concentrator Reactor
247-03	Tisch Environmental, Inc., University of Southern California (USC), Tisch Environmental, Inc.	Aerosol sampler
267-03	U478, INSERM U478	MTA
250-03	University of Minnesota-Duluth	confocal microscopy
133-96	University of Minnesota Large Lakes Observatory	Lake ecosystems
255-03	University of Virginia	MTA
299-04	US Triazole Task Force (USTTF)	MTA
288-03	Village of Nambe Pueblo	Arsenic removal
189-00	Waste Management Inc., Waste Management, Inc.	Municipal waste landfill bioreactgor
241-A-03	Wayne State University, University of Leeds, Wayne State University, University of Leeds	Male factor infertility
319-04	White Rock Water Company	Arsenic removal
275-03	W. L. Gore & Associates	MTA
268-03	Yellow Springs Instruments, Inc. (YSI)	Homeland Security-Water
246-03	, Intelligent Optical Systems, Inc.	Biological toxins in water
313-04	, LLC, Cooper Environmental Services LLC	X-ray analysis Software