Ms. Susan Dudley
Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
The New Executive Office Building
Room 5001
725 17th Street, NW Washington, DC 20503
Dear Ms. Dudley,
As you know, the Subcommittee has been working to understand the process by which the Office of Information and Regulatory Affairs (OIRA) at the Office of Management and Budget manages proposed entries to the Environmental Protection Agency’s (EPA) Integrated Risk Information System (IRIS). At our hearing on May 21, 2008 you portrayed OIRA’s role as one of simply coordinating an interagency process. However, documents that have come to the Subcommittee suggest that OIRA plays a direct role in examining and challenging the science that informs EPA’s proposed IRIS entries. I would like to assess exactly how much involvement OIRA has in discussions surrounding the science of IRIS proposals.
Because so many of the agencies that seek involvement in the IRIS interagency process may have clean-up or process issues at stake, it is hard to believe that interagency discussions are solely about the science. This is especially so since those agencies that may have pollution or workplace safety issues that would be implicated in IRIS data are not experts in the science of health or the environment. It is hard to see what expertise the National Aeronautics and Space Administration, to choose just one agency, brings to a discussion surrounding the health hazards associated with exposure to trichloroethylene. It would be very useful to the work of the Congress and the Committee to have a sense of what kinds of information is shared through the interagency process.
Finally, the interagency process OIRA manages is secret. The public has no insight into who is being invited to discuss what, when. The public has no way of getting at materials associated with those discussions because the pre-decisional exemption of the Freedom of Information Act (FOIA) applies to all of those materials.
