It’s outrageous. EPA has proposed a rule deceptively entitled “Strengthening Transparency in Regulatory Science.” Don’t believe the name. This rule would have the effect of denying our nation the benefits of some of the most significant environmental health science performed: epidemiological studies.
Epidemiologists study the distribution and determinants of health-related states or events (including disease), and then apply that knowledge to control diseases and other health problems. Their studies build knowledge about the relationship between environmental exposures and health outcomes.
EPA argues that these and other studies aren’t “transparent” because researchers suppress the names and other identifying information about the patients whose cases they study. But it would be unethical and illegal to release individual study participants’ data to the public. It would violate confidentiality requirements legally mandated by Institutional Review Boards and/or by HIPAA, the Health Insurance Portability and Accountability Act of 1996.
So for the EPA to propose to take into account only studies that reveal all content is a terrible idea. It would rule out some of the best science available, crippling our ability to study, understand and respond to significant environmental health threats.
And it gets worse: The proposed rule would be retroactive. That could deprive us of the protection provided by fundamental policies that safeguard and improve our health: the Clean Air Act, the Lead and Copper Rule of 1991, various pesticide bans, and other science-based policies that are underpinned by sound science using confidential human data.
Are you as outraged as I am? Then join me in urging the EPA to reject their own proposed rule. File your comment to the EPA here. Speak out! Science, knowledge and our health are on the line.