Cambridge, MA, Aug. 7th 2018 - Nearly 100 leaders in science and medicine from Harvard University have sent a letter to Acting Environmental Protection Agency (EPA) Administrator Andrew Wheeler detailing how a proposed rule titled "Strengthening Transparency in Regulatory Science" would damage America's health. The letter represents an unprecedentedly united front amongst leading experts in law, public health, science, engineering, and medicine in taking a strong stance against a proposed federal rule.
"Transparency is valuable and important. As used in the draft rule, however, transparency is a guise for excluding large bodies of valid--and best available--science." - Harvard science leaders on proposed rule 83 FED. REG. 18,768
The letter has been signed by people who are deeply involved in research that addresses the health impacts of chemicals and activities regulated by the EPA under its Statutes, which include the Safe Drinking Water Act and the Clean Air Act, among many others.
It adds important detail to the significant opposition mounted against the proposed rule, which would jeopardize the health of Americans by prohibiting the EPA from relying on high-quality, peer-reviewed scientific research - including most large-scale public health studies - when creating regulations.
The letter describes how the proposed rule would:
- Block the agency from fulfilling its statutory duty to protect public health by preventing it from relying on the best available research.
- Prevent the EPA from implementing its Statutes, including the Safe Drinking Water Act, the Clean Water Act, and the Clean Air Act, thereby jeopardizing the health and safety of infants, children, and adults in the United States and beyond.
- Reverse the EPA's sound practice of relying on research in public health and environmental exposure - including studies that are based on data that "cannot be made publicly available due to laws and contracts designed to protect patient privacy".
- Exclude valid research that cannot be repeated for ethical and humanitarian reasons, for example studies of Hiroshima and Nagasaki survivors that underlie the Safe Drinking Water Act.
- Undermine the research community's hard-earned methods and best practices - including peer review - for ensuring the transparency, reproducibility, replicability, objectivity, and validity of studies, analyses, models, and reports.
- Not serve its stated purpose of ensuring that regulatory decisions are based on "valid" science, rather preventing it from relying on the best research involving human participants.
Furthermore, the letter states, the proposed rule "creates these multiple problems without providing any significant countervailing benefits".
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This comprehensive, Harvard-faculty-led effort follows and expands upon a letter sent by former Harvard President Faust to the EPA in June. Its signatories include the President of Harvard University, Lawrence S. Bacow JD PhD; Harvard Law School Emmett Environmental Law & Policy Clinic director; the Dean and faculty of Harvard T.H. Chan School of Public Health; the Dean and faculty of Harvard Medical School; the presidents of Harvard-affiliated teaching hospitals, Beth Israel Deaconess Medical Center, Brigham and Women's Hospital, Massachusetts Eye and Ear, and Massachusetts General Hospital; and eminent faculty of the Harvard John A. Paulson School of Engineering and Applied Sciences, among many others.
The EPA's comment period for the rule is open until August 16th, 2018.