U.S. Environmental Protection Agency Administrator Scott Pruitt announced a proposed rule yesterday that would significantly restrict the types of scientific evidence that can be considered in EPA regulations. EPA’s proposal would require scientists to make the underlying private health data used in peer-reviewed studies of pollution and health publicly available before the studies could be considered by the agency.
As a former EPA scientist, it’s clear to me that this proposal would wreak havoc on EPA’s mission to protect the environment and human health: It would seriously diminish the pool of scientific research that it relies on to make key decisions and require a costly and time-consuming effort to make sensitive health data open to the public. The proposal would jeopardize the substantial progress our nation has achieved over the last 50 years in cleaning up our air, water, and land.
Air Pollution Harms Our Health
Consider the issue of air pollution. Many of the peer-reviewed studies EPA uses to set and revise National Ambient Air Quality Standards through the Clean Air Act (what EPA itself terms “pivotal regulatory science”) analyze the relationship between exposure to polluted air over many years and a range of adverse health effects. These comprehensive studies have enrolled thousands of American volunteers over periods ranging from several years to decades in order understand exactly how pollution harms us.
What these studies show, over and over, is that inhaling air pollution does indeed cause a wide array of health problems, from early death to heart disease, lung cancer, stroke, and asthma exacerbations. This troubling list seems to grow each day. To make that connection, these studies rely on detailed health, demographic, spatial (e.g., home address), and behavioral (e.g., dietary intake, smoking status, physical activity patterns) data from thousands of people. This information is extremely sensitive and collected at the individual level, and as such our nation’s health privacy laws and Institutional Review Board protocols require researchers to keep the data secure and confidential to prevent misuse. Collectively, these data points help researchers understand and isolate the cause-effect relationship between exposure to air pollution and risks for various health problems.
Proponents of the EPA policy change have suggested that privacy concerns surrounding the sharing of health data can be mitigated by anonymizing the individual-level health data that researchers collect. The reality is that such an undertaking would be immensely costly, complicated, and slow—and deliver no net benefit to EPA or the American public. The cost projections are staggering: when EPA staffers in 2017 considered the potential effects of failed legislation that inspired Pruitt’s latest move, they calculated that efforts to anonymize health data and confidential business information could top an astounding $250 million each year (more than 3% of the agency’s budget, and potentially up to $1 million per study) for the already strained agency workforce—huge amounts of taxpayer money and staff time that would be much better spent on implementing our nation’s environmental laws.
EPA Has Relied On This Science For Decades
Strong peer-viewed scientific research has long helped to set our nation on a course for cleaner, healthier air. Groundbreaking studies like the Harvard Six Cities Study examined the health effects of air pollution over 16 years on more than 8,000 adults and 14,000 children. It found a significant relationship between air pollution exposure and risk of early death, but the raw data could not be released publicly because researchers were obligated to ensure study participant confidentiality. Still, relying on that data, more than 100 peer-reviewed studies have confirmed the basic results of that initial study. Because the study and others like it advanced through the rigorous peer-review process characteristic of the world’s leading scientific journals (whose editors have rejected the proposed rule), EPA relied on their results in 1997 when it promulgated the first-ever National Ambient Air Quality Standards for fine particulate matter (PM2.5), by far the most dangerous air pollutant. Since then, literally hundreds of additional studies into the health effects of air pollution (conducted across the country and internationally, for both short- and long-term impacts of exposure) and independent re-analyses of existing datasets have affirmed the air pollution-mortality and morbidity links with increasing precision. In 2000, the Health Effects Institute published its independent reanalysis of the Harvard Six Cities study, which confirmed the original findings.
EPA has rightly continued to rely on the robust peer-reviewed literature to inform the air quality standard-setting process year after year, incorporating the best available scientific evidence in epidemiology, toxicology, and exposure assessment to set the outdoor air quality standards at levels that protect public health and the environment. It has also (until recently) agreed with leading scientists who’ve spent their careers studying air pollution and health that no safe threshold of fine particulate air pollution exists. The National Ambient Air Quality Standards and Clean Air Act’s designations process have helped to clean up our nation’s air in substantial ways since 1970, and have protected millions of Americans, young and old, from breathing polluted air that would harm their health.
Our Environmental Progress At Risk
To top it off, Pruitt’s proposal unfairly applies only to “pivotal regulatory science” and may not subject proprietary data and modeling tools used by industry to public scrutiny or peer-review. The problems with Pruitt’s proposal go well beyond impacts on air pollution policy; for helpful summaries, read my colleague John Walke's letter to the House Science Committee in 2014 and my colleague Dr. Jennifer Sass' blog on how the proposed rule favors confidential industry-funded work over public, peer-reviewed health studies.
Censoring Science, Endangering Our Health
EPA’s application of peer-reviewed science in implementing the Clean Air Act and National Ambient Air Quality Standards represents the best of America’s global environmental leadership, and it serves as the template for other countries seeking to address the harmful effects of air pollution. Why should we change our approach now and limit the scope of scientific research that EPA can consider? Pruitt has suggested that data “transparency” and “independent validation” of results will benefit us all, but the truth is that independent validation is happening now. This proposal is designed to hamstring EPA’s work, drain its already limited resources, and cast doubt on the integrity of robust, decades-long scientific studies that have helped to inform and advance our nation’s best environmental and health safeguards. Pruitt’s EPA is politicizing science, yet again, in hopes of distracting us from his disastrous environmental and ethical record.
Related Blog Posts
Trump's EPA has announced plans to try to repeal the Clean Power Plan—and deny Americans annual health benefits that include avoiding 3,600 premature deaths; 90,000 asthma attacks in children; 1,700 hospital admissions; and 300,000 missed days of school and work.
The Trump Administration’s analysis of the impacts of rolling back the Clean Power Plan relies on misleading accounting, attacks the overwhelming consensus of health experts, and engages in climate denial.