EPA Begins Public Comment Period on CRA Guidelines for Planning and Problem Formulation – Update from Bergeson & Campbell, P.C.

The U.S. Environmental Protection Agency (EPA) announced on June 16, 2023, a 60-day public comment period on the draft Guidelines for Cumulative Risk Assessment Planning and Problem Formulation (draft CRA Guidelines). 88 Fed. Reg. 39424. According to EPA, the draft CRA Guidelines describe steps for the planning and problem formulation of CRAs and offer guidelines for when CRAs could be appropriate. Planning defines both the process for conducting the risk assessment and its general scope, while problem formulation identifies major factors considered in a specific assessment to inform its technical approach. EPA notes that the draft CRA Guidelines “are not final, and do not represent, and should not be construed to represent, Agency policy or views.” Comments are due August 15, 2023. The draft CRA Guidelines provide methods and procedures for CRA planning, “a necessary step in the advancement of CRA from a concept to a decision-relevant tool.” The draft CRA Guidelines comprise three sections. For more information, please read the full memorandum.

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