Gradient

Global Regulatory Compliance

Scientific Comment

Overview
Example Projects
Experts

Overview

Gradient provides written comments and supporting analyses regarding a variety of proposed rules, guidance documents for the regulated community, and draft chemical assessments under the TSCA and IRIS programs. Gradient is often asked to present comments at US EPA scientific committee meetings to help the agency develop science policy. We have also testified before federal and state Congressional committees regarding proposed legislation, bringing scientifically sound perspectives to inform the legislative process.

Government Building

Example Projects

Regulatory Comment – Lead

Full Description

Gradient provided oral and written comments on numerous US EPA documents prepared during reviews of the National Ambient Air Quality Standard (NAAQS) for lead. Our comments focused on critiques of the air lead/blood lead relationship and human health effect studies used to support decision-making.

Regulatory Comment – Coal Combustion Waste (CCW)

Full Description

Gradient critiqued a US EPA risk assessment on CCW in landfills and surface impoundments. We evaluated the appropriateness of parameters used in the probabilistic risk assessment and the inputs selected for fate and transport modeling of metals (MINTEQ). Our review identified several areas of uncertainty in the modeling and risk assessment.

Regulatory Comment – Ozone, PM, NOx and SOx

Full Description

Gradient provided oral and written comments to the Clean Air Scientific Advisory Committee (CASAC) on clinical and epidemiological studies and their bearing on US EPA's development of NAAQS for ozone, particulate matter (PM), nitrogen oxides, and sulfur oxides.

Risk-based Support for Use of Wood Preservative Chemical

Full Description

Gradient engaged in discussions with Health Canada's Pest Management Regulatory Agency regarding approval of our client's wood preservative, which contained copper and tebuconazole, for continued residential and commercial uses. Gradient developed a human health risk assessment demonstrating that the proposed uses were safe and provided information regarding the chemical leachability of wood preservatives based on studies performed by the client.

Comment on Connecticut Proposed Regulations

Full Description

Gradient commented on proposed revisions to CT DEEP's Remedial Standard Regulations. We assessed the basis of proposed groundwater volatilization and surface water protection criteria for petroleum hydrocarbon fractions and the compared proposed levels to those expected to pose risk to human health or the environment.

Experts

Barbara D. Beck Read Bio

Teresa S. Bowers Read Bio

Catherine Petito Boyce Read Bio

Julie E. Goodman Read Bio

Lorenz R. Rhomberg Read Bio