Conrad Law & Policy Counsel
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Science Policy / Information Quality

 
Capability:

Over the course of his career, Conrad has developed formidable skills in advocating his clients' interests in the highly complex scientific and technical areas that underlie environmental, health and safety regulation. He is conversant in the language of toxicology, epidemiology, exposure assessment and risk assessment, and understands governmental policies for standard-setting in these areas. He has played a crucial role in catalyzing significant changes in the processes used for EPA's IRIS database and the National Toxicology Program's Report on Carcinogens, and in obtaining greater Congressional funding for IRIS.

At the close of the Twentieth Century, these 'use of science in regulation' issues became a special case in the emerging controversy about how federal agencies use information for policy purposes. Conrad has been centrally involved in these debates throughout that time. At the core of these disputes is the Information Quality Act (IQA), on which Conrad is particularly expert. In addition to OMB's and EPA's IQA Guidelines, Conrad is also deeply familiar with OMB's Peer Review Bulletin and its Bulletin on Good Guidance Practices. He works regularly, and has published and spoken widely, on the questions of conflict of interest and bias in connection with scientific work and scientific review panels. Conrad also understands the issues associated with human subjects research.

 
Track Record:

  • Consult regularly with a Fortune 50 company and occasionally with ACC on issues involving federal agency reliance on industry-supported science and industry scientists.
     
  • Currently help lead efforts to improve the processes used by EPA's IRIS database; drafted, negotiated earmarks and report language adopted in multiple Congresses regarding IRIS.
     
  • Have assisted the Styrene Information and Research Center with an Information Quality Act (IQA) correction request regarding a Background Document prepared by the National Toxicology Program for its 12th Report on Carcinogens.
     
  • Represented a major company in successful effort to head off legislative efforts to ban or restrict an important product.
     
  • Advised a large industrial trade association in connection with Congressional oversight of EPA's chemical management.
     
  • Have assisted several trade associations in comments on the President's memorandum on scientific integrity and on EPA and OSHA risk assessment practices.
     
  • Drafted ACC's comments and led ACC's advocacy regarding: OMB and EPA's Information Quality Act Guidelines; OMB's Peer Review Bulletin; OMB's Bulletin on Good Guidance Practices; OMB's proposed Risk Assessment Bulletin; and EPA's rules on Human Subjects Research.
     
  • Prepared a major IQA correction request for a national association; have informally advised several parties in IQA correction requests and subsequent litigation.
     
  • Invited to serve on a Transparency & Public Participation Task Force organized by the University of Pennsylvania Law School for OMB Watch. (The Task Force's report, published at 77 Geo. Wash. L. Rev. 924 June 2009), is available at http://docs.law.gwu.edu/stdg/gwlr/issues/pdf/Coglianese-77-4.pdf.)
     
  • Invited to participate in University of Pennsylvania School of Medicine Center for Bioethics conference on conflict of interest in energy & biomedical science.
     
  • Stopped EPA's "Third-Party Assessment Factors."
     
  • Former president of the Coalition for Effective Environmental Information.
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