EPA’s Pretense of Science: Regulating Phantom Risks
•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.