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Comment on
Docket ID: EPA-HQ-OA-2018-0259
Comment Tracking Number: 1k2-94w2-3hnj

I oppose this proposed rule which is a tacit attempt to do away with environmental regulation. We need more protection from pollution, not less. Clean air & water are even more important since the FDA permits more radiation in Americans’ food than any other country. Increased oil & gas production-injection wells also make regulation more important than ever, as does the problem of nuclear reactor dismantlement-nuclear waste.

The EPA news release for the proposed rule references Ed Calabrese who has long worked as a hired gun, masquerading as a scientist, for Exxon, Big Tobacco, as well as the military. Initially, it was unknown if chemicals or radioactive material (polonium) in cigarettes caused cancer – it is both. So, he begin pushing the lie that some toxic chemicals and radiation is healthy (aka hormesis). His latest version pretends that BEIR hasn’t updated anything since the 1950s. This is false. The most recent BEIR even allowed Calabrese to present his hormesis case, but he failed to convince experts.

Dr. Weatherwax, Ph.D. in biochemistry, explained to Congress in Sept 2016 that despite 18 years of research & over a quarter of a billion dollars of funding that the DOE Office of Science has devoted to the Low Dose Research Program: “To date, there are no studies that have been able to establish with sufficient certainty a threshold level of radiation below which a risk of cancer is zero, despite decades of research in this area….the LNT model continues to be the accepted, albeit conservative, standard on which current radiation worker protection standards are based. Current National and International bodies (National Council on Radiation Protection and. Measurements, NCRP; International Commission on Radiological Protection, (ICRP) continue to recommend the use of the LNT”

Increasing numbers of studies show that ionizing radiation is even more dangerous than thought in the 1950s. There was a recent 2015 study of nuclear workers showing increased cancer-deaths for a (12 yr avg) career cumulative exposure of 4.1 mSv, which is 0.34 mSv per yr – only slightly above the EPA’s 0.25 mSv per yr exposure limit for the general public from nuclear facilities. This supports linear no threshold (LNT), i.e. No Safe Dose of Ionizing radiation-increased dose is increased risk.

Calabrese & his associates at SARI-Carol Marcus at UCLA pretend that 100 mSv per year is low dose, but it is intermediate dose. 100 mSv per yr would guarantee life-shortening cancer for all. Mark Miller, formerly of Sandia-Lockheed Martin & now of SARI, who wrote EPA-Pruitt in March 2017, demanding what appears to be the current EPA proposed rule, has called for exposures as high as 20,000 mSv per yr, which would guarantee cataracts, heart disease, infertility, & possibly chronic radiation syndrome. 5 yrs of 100 mSv per yr leads to cataracts & heart disease according to the ICRP.

I support comments by the International Society for Environmental Epidemiology. They note that the proposed “parametric forms by their nature can force dose-response curves into shapes not indicated by the data… We know of no epidemiology society that recommends EPA’s approach.”

I support comments by the National Tribal Air Association. They note that the “term “pivotal regulatory science” seems “to be the main focus for this rule”, but “is not defined” and “does not appear anywhere else in the legal records, court decisions, or rules that address environmental protection or the role of the EPA.”

They & others note that the proposed rule is illegal on multiple grounds & that it “is strikingly similar to both the Honest and Open New EPA Science Treatment (HONEST) Act of 2017 (H.R. 1430 … ) and the Secret Science Reform Act of 2014 (H.R. 4012 … ) and 2015 (H.R. 1030…), all of which repeatedly failed to pass in the Senate despite being supported by the energy, manufacturing, and chemical industries. All of these nearly interchangeable bills would have required all research data used in agency actions to be made available to the public. This is a problem from the viewpoint of participant confidentiality…. Individuals typically will only agree to participate if their health information is kept confidential. This proposal calls for “replication” and “reproducibility” of studies, yet there are questions within the scientific community as to what these terms mean, and to what degree they are needed….scientific replication is not attained by simply repeating the exact details of an experiment – that is from a grade school science class. Replication is best achieved when the findings of the initial study are supported by other studies approaching the same question in different ways”. Thus, this proposed rule is a means of by-passing the US Congress.

At least 39% of those signing SARI-Mark Miller’s petition to the EPA are foreigners. This should also raise alarm.”

The comment period is now closed. Comments can be seen here: https://www.regulations.gov/docket?D=EPA-HQ-OA-2018-0259 Docket ID: EPA-HQ-OA-2018-0259. Feel free to still email complaints to EPA, but they aren’t required to consider or post them.
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