It’s common sense: the environment matters to our health.
Ask parents, teachers, nurses, and community leaders, and they get it. They know that air and water pollution, contaminated land, and chemical exposures in their homes, schools, workplaces, and communities can cause serious health effects – both acute and chronic. Families and communities across the country value a clean environment and rely on strong public standards, based in science, to give them the protection they need, expect, and deserve.
That’s why the Environmental Protection Agency (EPA) was created. It is a critical public health agency whose primary mission is to “protect human health and the environment.” Unfortunately, its track record over the last year-and-a-half has not been good. We have seen the agency sideline science and run in the opposite direction—delaying, weakening, and rolling back public health protections and ignoring the advice of its own scientific experts and advisors. Whether considering pesticides and toxic air emissions or the safety of chemical facilities, the EPA has been stepping back from its primary mission and putting public health at risk.
Now the agency plans to go one step further. It’s proposing a rule to ensure it doesn’t have to use the best available science to make public health and environmental decisions. Next week (July 17), EPA will hold its only public hearing on the proposed rule called “Strengthening Transparency in Regulatory Science.” That sounds like a good thing, but it is a deceptive title and a threat to our health. It turns out that this proposal is really an effort to allow EPA to restrict the science it uses for decision making.
In examining the relationship between public health and environmental pollution, EPA is proposing to eliminate consideration of scientific studies unless the raw study data are made publicly available — possibly including participants’ personal, confidential, and private information — data that may be subject to legal, ethical, and human subject research protections.
This requirement would eliminate human health studies that use integral medical, lifestyle, and geographic data, as well as studies that include confidential business information, such as information from studies conducted by industry to demonstrate safety of a pesticide or other toxic chemical. It could also eliminate consideration of older studies for which data are no longer available or accessible, even if the data have been reanalyzed and the studies have been validated, replicated, reproduced, and undergone rigorous and independent peer review.
Far from using the best available science for EPA decision-making, the proposal would severely limit the studies and scientific evidence the agency would use to fulfill is statutory mission to protect human health and the environment. This is not a new idea. It is the result of a decades-long campaign to undercut reliance on groundbreaking research that definitively linked exposure to fine particulate matter (PM) to premature death and prompted the first regulation of PM under the Clean Air Act. For example, Harvard University’s “Six Cities” study has been anathema to lobbyists in regulated industries for a long time.
EPA provides no analysis of the need for or the potential impacts of the proposed rule. The agency did not consult with critical stakeholders, including scientists and health professionals in developing the proposal. It did not consult with the prestigious National Academies of Science, Engineering and Medicine or even its own hand-picked Scientific Advisory Board (SAB), whose members found out about the proposed rule via a press event, news articles, and an announcement in the Federal Register. In its June 28, 2018, letter to then EPA Administrator Scott Pruitt, the SAB chair urged the agency to request, receive, and review scientific advice from SAB before revising the proposed rule.
Science organizations, scientists, public health, and medical professionals from across the country have urged the EPA to withdraw the proposed rule. The editors of major scientific journals issued a joint statement opposing and objecting to EPA’s claim that the rule is consistent with scientific community norms.
In its joint letter of June 1, 2018, the American Academy of Pediatrics and the American College of Obstetricians and Gynecologists wrote that “The proposed rule would drastically and incorrectly limit the types of scientific data that EPA can use when making substantial regulatory changes. Implementing this rule will harm the health of children and pregnant women by causing EPA to disregard some of the best available scientific studies examining the effects on these vulnerable populations from lead, harmful chemicals, fine particle pollution, and contaminants.”
The American Public Health Association, Physicians for Social Responsibility, and a host of other public interest organizations jointly called on the agency to withdraw the rule, noting that it “significantly departs from long-standing policy at EPA and is inconsistent with well-established practices used throughout the scientific community.”
And in a May 8, 2018, letter, 300 public health scientists and professionals noted that “If finalized, the proposed rule could place unprecedented limits on the use of scientific evidence by EPA. These limits will in turn shape the development of evidence-based public health policies including air pollution standards, drinking water regulations, pesticide tolerances, worker protections, and more.”
As public health professionals with years of experience in academia, government, and the non-profit sector, we have witnessed political interference and shifting tides on core policy issues across both Democratic and Republican administrations. But EPA’s newly proposed restrictions on the body of scientific evidence it will consider in its regulatory decision making is a fundamental threat to public health, and it will seriously erode the agency’s ability and responsibility to protect it.
Make your voice heard by submitting comments on the proposed rule via Regulations.gov to docket EPA-HQ-2018-0259 by August 16, 2018. This proposal is a dangerous threat to your health.