This commentary is in response to the remarks of Drs. Christina Sobin, Mari Golub, and David Herr on the Special Issue of this Journal entitled "Assessment of Learning, Memory, and Attention in Developmental Neurotoxicology Regulatory Testing." I endorse the views expressed by Drs. Sobin, Golub, and Herr and add some discussion on a recent Organization for Economic Cooperation and Development (OECD) guideline, the Extended One Generation Reproductive Toxicology Guideline (OECD 446), in which testing for higher cognitive function (learning and memory) has been eliminated. The case against this decision is offered. It is noted that deficits in higher cognitive function are one of the hallmarks of human studies that find neurobehavioral toxicity in children after exposure to environmental agents such as lead, methylmercury, PCB, pesticides, and other environmental agents. It is noted that the OECD decision is at variance with the views of the scientific community in this field, including those of Drs. Sobin, Golub, and Herr. Why OECD took such action without the advice and consent of the field of developmental neurotoxicology is deeply concerning and potentially hazardous to children. I also endorse Dr. Herr's recommendation that in the future the Environmental Protection Agency negotiate study designs in advance with submitters as the Food and Drug Administration does to improve data quality for all neurobehavioral methods, and especially for tests of learning and memory that have not been adequately conducted in many past studies.