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EPA’s Pretense of Science: Regulating Phantom Risks

From the Perspective of a Former Environmental Regulator
Key Points:

•Congress should reclaim its authority to make the major policy decisions under federal environmental law.

•The CAA needs to stipulate minimal criteria for risk assessment of health effects to include:

•EPA risk assessment must be peer-reviewed by truly independent body.

•Toxicological studies and clinical trials carry more weight than Epidemiological studies.

•Abandon the no-threshold linear regression modeling assumptions.

•Use representative estimates of actual exposure and not implausible worst-case scenarios.

•Physical measurement trumps models.

•Plausible biological mechanism - prerequisite of health-effects findings.

•We need a comprehensive, cumulative cost-benefit analysis of all rules.

•Make EPA’s risk assessments judicially reviewable.