Items to consider when drafting, re-drafting, and reviewing CDR partial exemption requests

   1. All considerations have concluding remarks.

   2. Statements are clearly conveyed as being those of the Petitioner or those of the Agency.

   3. If the Agency utilizes a model estimate to calculate an endpoint, then the model version and SMILES notation are footnoted, along with a statement of whether measured values were used for estimating the endpoint.

   4. The document is internally consistent with regard to statements made under each consideration.

   5. All considerations are critically reviewed for logic errors, and each consideration is presented in a logical order.

   6. Justifications are clearly articulated.  For example, if one consideration is weighted more heavily than another, then the rational and justification need to be provided.  Another example applies to accepting/rejecting:  study summaries, studies in general, model estimates, or determinations from other governmental entities (e.g., FDA, ECHA, etc.).

   7. Spelling/grammar/abbreviations/formatting/references (Stay consistent with the draft PKO petition.)
