Preparing a Citizens Petition

The term unreasonable risk is not defined in the statute, but... Congress intended EPA to balance the benefits derived from risk reduction against the social and economic costs incurred, taking into account such factors as the extent and magnitude of risk imposed the societal consequences of removing or restricting use of products availability and potential hazards of substitutes and impacts on industry, employment, and international trade. 50 Fed. Reg. 45825, 46826 (Nov. 13,1985). 

In addition to the general information noted above, EPA recommended particular information be included based upon the provision of the statute upon which relief is being sought. Petitions seeking to initiate a test rule under 4 should provide data to demonstrate  

The petition must also explain how the data developed from the test rule will help resolve the problem identified in the petition.  

Petitions seeking to initiate an order under 5(e) prohibiting or limiting the manufacture, processing, distribution in commerce, use, or disposal of a new chemical should provide data to demonstrate  

Petitions seeking to initiate an order under 6(b)(2) requiring a description of, and if necessary changes to, a company s quahty control procedures, should provide information to demonstrate a reasonable basis to conclude that the chemical is produced in a manner which unintentionally causes an unreasonable risk.  

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