A commentary reviewing the U.S. Environmental Protection Agency’s (EPA) current disclosure practices calls for data used in chemical evaluation to be disclosed. In particular, raw data, methods and models used should be made publically available. Such practice would increase the chemical assessment’s quality (Lutter et al. 2013). The commentary was published February 1, 2013 in the journal Environmental Health Perspectives and based on the proposal of experts during a meeting on the assessment of the quality of scientific work in chemical evaluation. Increased transparency of chemical evaluations would allow independent scientists to reproduce the analysis. Better transparency would also increase citizens’ trust in regulatory decisions.

The recommendation of the experts was based on the case of pesticides’ evaluation carried out by the U.S. EPA. However, it may be applied to other chemicals and other regulatory agencies. The U.S. Food and Drug Authority (FDA), which is responsible for food packaging safety in the U.S., carries out both risk assessment and risk management using a variety of models. Chemical exposure is modeled on the basis of consumption and food-type distribution factors (Alger et al. 2013). It is not fully disclosed how these are derived from dietary and market data by the FDA.

Hence, the application of disclosure practices like those suggested to the U.S. EPA by Lutter and others would allow the replicability of chemical evaluations carried out by the FDA and allow an assessment of their scientific quality.


Lutter, R. et al. (2013). Data Disclosure for Chemical Evaluations. Environ Health Perspect 121:145–148.

Alger HM, et al. (2013). Perspectives on how FDA assesses exposure to food additives when evaluating their safety: Workshop proceedings. Comprehensive Reviews in Food Science and Food Safety 12:90-119.