On March 21, 2006, WLF requested that the Environmental Protection Agency (EPA) reconsider its earlier decision to decline to consider a WLF petition to eliminate “junk science” from the process by which EPA determines whether a substance is likely to cause cancer in humans. In a petition filed pursuant to the Information Quality Act (IQA) in August 2005, WLF had argued that EPA guidelines for determining human carcinogenicity violate the IQA because they are not based on sound science but rather on an EPA policy judgment that extreme caution should be adopted in connection with substances that pose any possible cancer risk. EPA’s response asserted that because its guidelines constitute a “policy” document, they are not subject to the IQA. WLF’s March 21 reconsideration petition explains why EPA policy documents are not exempt from the IQA. WLF filed its initial petition and its reconsideration request on behalf of itself and the American Council on Science and Health (“ACSH”).
