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Excerpts: “We the undersigned scientists and health care providers implore US EPA to rescind the “Transparency” proposed rule (EPA-HQ-OA-2018-0259-9322) completely because it threatens both the environment that supports human existence and environmental public health…. we conclude that the proposed supplement would lead to failure of EPA to fulfill its functions of protecting the environment and environmental public health, to subversion of environmental science and environmental health science by undue influence of regulated industries, and to strangulation of science both at the level of consideration of the studies used for policy and regulation and at the level of producing science based on volunteers.” See letter in its entirety after links.

Comment on the Environmental Protection Agency (EPA) Proposed Rule: Strengthening Transparency in Regulatory Science” Related information, Open Docket Folder and comment here:
https://www.regulations.gov/docket?D=EPA-HQ-OA-2018-0259
Information-comments from the earlier comment period two years ago:
https://miningawareness.wordpress.com/2018/05/25/trump-pruitts-epa-announces-extended-comment-period-and-public-hearing-on-so-called-transparency-rule/
https://miningawareness.wordpress.com/2018/05/20/nearly-1000-scientists-tell-trump-pruitt-epa-dont-restrict-epas-ability-to-rely-on-science-comment-by-may-30th/
https://miningawareness.wordpress.com/2018/08/16/trump-epa-proposal-re-dose-response-analysis-is-inappropriate-and-not-scientifically-based-say-epidemiologists-comment-by-thursday-night-1159-pm-eastern-time/
https://miningawareness.wordpress.com/2018/08/15/national-tribal-air-association-comment-opposing-proposed-us-epa-rule-comment-deadline-thursday-night-1159-pm-eastern-time/
https://miningawareness.wordpress.com/2018/08/15/the-president-of-harvard-university-letter-opposing-proposed-us-epa-rule-comment-deadline-thursday-night-1159-pm-eastern-time/
https://miningawareness.wordpress.com/2018/08/11/trump-epa-cost-benefit-analysis-pre-rulemaking-comment-deadline-is-monday-august-13th-11-59-pm-eastern/
https://miningawareness.wordpress.com/2018/05/08/new-york-attorney-general-tries-to-protect-people-environment-from-100-fold-increase-in-radiation-and-other-toxic-dangers-gets-accused-of-abuse/

Comment submitted by the undersigned (Emphasis our own):
Hon. Andrew Wheeler, Administrator
US Environmental Protection Agency
Mail code 1101A
1200 Pennsylvania Avenue NW
Washington DC 20004

To Hon. Andrew Wheeler, Administrator of US EPA:

We the undersigned scientists and health care providers implore US EPA to rescind the “Transparency” proposed rule (EPA-HQ-OA-2018-0259-9322) completely because it threatens both the environment that supports human existence and environmental public health.

1. The rule requires public availability (either directly by publication or indirectly through a tiered access program) of all data, analyses, and models that support new environmental policy (“influential and highly influential scientific information”) and regulatory standards. Much environmental health data come from confidential medical records (cohort studies and birth and death certificates) that cannot be posted without risk of re-identification of individuals even if the most advanced techniques of de-identification are applied. This rule breaks laws, best practices and ethics of medical privacy.

2. The rule could also apply to current standards as they come up for renewal. Thus, the current limits on health-threatening pollution could also come under this privacy-destroying rule.

3. The rule would assign no weight or less weight to studies that cannot make the data available even if they are the ones with highest scientific quality. Thus, new and renewed standards would be based on science of less than highest quality. The omission of the privacy-protecting studies would greatly diminish the strength of meta-analyses needed for high quality science. Decision-makers may even refuse to set a needed standard on the excuse that the evidence lacked sufficient weight.

4. The rule would create a massive database on a website, inviting hacking both by parties with commercial interest in laxness of standards and by hackers who are either pranksters or who use ransomware. Hackers could falsify data and analyses, erase data and analyses, and re-identify individuals. Hacking has become one of the most expensive and disruptive crimes. Hacking by corporations is so common that the Cyber Infrastructure Agency of Homeland Security gives it a class by itself.

5. This rule opens the policy- and standard-setting processes to interminable debate through “reanalysis”, “alternative models”, and “independent validation” by well-funded consultants and direct employees of the regulated industries. Needed policy and standards would be either grossly delayed or even killed.

6. This rule shows no recognition of the influence of conflicts of interest on scientific results and provides no assurance of testing and correcting for conflicts of interest. Indeed, it appears to invite distortion of science by conflicts of interest.

7. This rule fails to recognize the social science of informed consent and of broad informed consent which indicates that fewer volunteers would participate in environmental health research if they knew that their data would be posted and would be available to for-profit industries. Privacy is very important to volunteers. The new 2017 Common Rule with which EPA must comply requires use of the broad informed consent form for studies that would post data. Certain classes of potential volunteers shy away from giving broad consent. Thus, this rule would severely impair development of science.

8. This rule usurps the debate function of the larger scientific community in deciding what is influential and highly influential scientific information, what science is appropriate to support influential and highly influential scientific information and regulatory standards, and the methods for making these decisions. This rule ignores the evolution of this debate and the knowledge of this important function of the scientific community from the disciplines of philosophy of science, history of science and sociology of science.

Thus, we conclude that the proposed supplement would lead to failure of EPA to fulfill its functions of protecting the environment and environmental public health, to subversion of environmental science and environmental health science by undue influence of regulated industries, and to strangulation of science both at the level of consideration of the studies used for policy and regulation and at the level of producing science based on volunteers.

In alphabetic order

Name title institution*

1) Sasha Adkins lecturer, environmental health Institute of Environmental Sustainability, Loyola University, Chicago

2) Rosemary Ahtuanganak Nuiqsut, member CDC/APHA Tribal Public Environmental Health Thinktank Alaska

3) Mary K. Anglin, Ph.D., MPH Associate Professor Dept. of Anthropology, U. Kentucky

4) Elgin Avila Ph.D. student/NIOSH trainee University of Minnesota

5) Jamie Banks, Ph.D, MS Executive Director Quiet Communities, Inc.

6) Gloria E. Barrera, MSN, RN, PEL-CSN President-Elect, Illinois Association of Nurses

7) Mark Brotman, MPH Senior Research Scientist

8) Erika Brown, Ph.D. candidate U.California, Berkeley

9) Velma Campbell, MD, MPH Occupational Medicine Resources, PC

10) Linda Campbell Detroit, Michigan

11) Dana Carlson, MPH President Peak to Peak

12) Janine Caruso, RN, BSN, M ED Clinical RN, Ob/Gyn Altrius Health

13) Susan B. Cashman, ScD, MS Professor and Director of Community Health,

U. Mass. Medical Schl.

14) Mary Ann Castle, Ph.D. Senior Associate Planning Alternatives for Change

15) Avik Chatterjee, MD, MPH Assistant Professor Boston U. School of Medicine

16) Richard Clapp, Ph.D. Professor Emeritus Boston University School of Public Health

17) Chris M. Coombe, Ph.D. MPH Assistant Research Scientist U. Michigan Schl of Public Health

18) Robin Cooper, MD Clinical Professor of Medicine University of California, San Francisco

19) Lauri Costello, MD Saba University School of Medicine

20) Hannah Covert PhD Research Assistant Professor Tulane University

21) Richard Crume Governing Councilor American Public Health Assn.,

Retired from USEPA Office of Air Quality Planning and Standards

22) Robin Evans-Agnew, RN, Ph.D. Associate Professor School of Nursing and Health Leadership University of Washington, Tacoma

23) Jerald A Fagliano, PhD, MPH Clinical Associate Professor, Chair, Dept of Environmental and Occupational Health, Dornsife School of Public Health, Drexel University

24) Joseph Feinglass MD Research Professor of Medicine, Div. General Internal Medicine and Geriatrics, Northwestern University Feinberg School of Medicine

25) H. Christopher Frey Ph.D., Glenn E. Futrell University Professor North Carolina State University

26) Elizabeth Friedman, MD, MPH Kansas City, MO

27) Samuel Friedman, Ph.D. Research Professor Department of Population Health

New York University Grossman Medical School

28) Victoria Frye, MPH, Dr. PH, Associate Medical Professor Dept. Community Health and

Social Medicine, CUNY School of Medicine, City College of New York

29) Elizabeth Geltman, Ph.D. Associate Professor City U. of New York, Schl of Public Health

30) Robyn Gilden PhD, RN University of Maryland School of Nursing

31) Robert Gould, MD Associate Adjunct Professor

Program in Reproductive Health and the Environment, UCSF School of Medicine

President Physicians for Social Responsibility, SF Bay Area Chapter

32) Gene Grabiner, Ph.D. Distinguished Service Professor Emeritus State University of New York

33) Elizabeth Haase, MD Associate Professor of Psychiatry, University of Nevada Schl of Medicine, Reno

34) Heidi Hanson, PhD Assistant Professor Huntsman Cancer Institute, University of Utah

35) Michael Heumann, MPH, MA Heumann Health Consulting, LLC

36) Kenneth A. Hirsch, MD, PhD retired

37) Jyostna Jagai, MS, MPH, PhD Research Asst. Professor Environmental and Occupational Health Sciences Division, School of Public Health, University of Illinois at Chicago

38) Jacky M. Jennings, Ph.D., MPH Associate Professor Depts of Pediatrics and Epidemiology, Associate Director, General Pediatrics and Adolescent Medicine, Johns Hopkins School of Medicine

39) Tabitha E Johnson, MPH Liberty University

40) Henry S. Kahn, MD Professor Emeritus Emory University School of Medicine

41) Marjorie Kircher, MS OTR retired pediatric occupational therapist, OR PSR, Env. Health Comm.

42) Katherine H. Kirkland, DrPH, MPH Instructor George Washington University

43) Rachel Kreier, Ph.D. Associate Professor of Economics St. Joseph’s College, Patchogue

44) Patricia Kullberg, MD, MPH retired Medical Director and asst. health officer

Multnomah County Health Department

45) Megan Latshaw, PhD, MHS Dept. of Environ. Health and Engineering, Johns Hopkins

Bloomberg School of Public Health

46) Betty Wolder Levin, Ph.D. Professor Emeritus Dept. of Community Health and Social

Sciences, CUNY Graduate School of Public Health and Health Policy

47) Carly Levin, DHS,MPH, CPH Asst. Professor of Public Health, Director of Master of Public Health Program, MCPHS University

48) Ann Loree, MSPH Assistant Health Agent Westminster, VA

49) Cynthia Mahoney, MD leader in Climate Health Now Berkeley, CA

50) Emily Marte, MPH Health and Safety Specialist, NY Comm. Of Occupational Safety and Health

51) Ashley McClure, MD leader in Climate Health Now Oakland, CA

52) Kristen McCormack Naturopathic doctor Metabolic Maintenance

53) Katlyn McGraw Ph.D. candidate University of Louisville

54) Rachel McIntosh-Kastrinsky Medical Advocates for Clean Air manager, Clean Air Carolina

55) Amanda Millstein, MD leader in Climate Health Now Richmond, CA

56) Dr. Aziz R. Molla Associate Professor Schl of Health Sciences Grand Valley State University

57) Rachel Morello-Frosch Professor School of Public Health, U.C. Berkeley

58) Hillary Nelson, Ph.D., MPH Director of MPH Program University of Pennsylvania

59) Michele Okoh, J.D. Senior Lecturing Fellow Duke Environmental Law and Policy Center, Duke University

60) Brock O’Neil, MD Asst. Professor Huntsman Cancer Institute, Univ. of Utah

61) Jessica O’Neill, MPH PhD candidate University at Buffalo

62) Joshua Osowiecki student Monrovia College

63) Rebecca Parkin, PhD, MHP professional lecturer George Washington University

64) Frederica P. Perera, Dr. PH, Ph.D., Professor of Public Health, Director of Translational

Research, Founding Director of Columbia Center for Children’s Environmental Health

Mailman School of Public Health, Columbia University

65) Janet Perlman, MD, MPH Professor of Pediatrics University of California, SF

66) Marsha Presley, Ph.D., MPH Research Associate/Adjunct Faculty A. T. Still University

67) Jean Rabovsky, PhD retired retired

68) Joemy Ramsey, Ph.D. Postdoctoral Fellow, Huntsman Cancer Institute,

University of Utah

69) Dannie Ritchie MD, MPH Clinical Asst. Professor of Family Medicine Brown University

Founder of Community Health Innovations of Rhode Island

70) Beth Rosenberg Associate Professor Tufts University School of Medicine

71) Leslie Rubin, MD Break the Cycle of Health Disparities, Atlanta

72) Paola Rullan, MPH-VPH Veterinary Educational Programs Coordinator, College of

Veterinary Medicine, Dept. of Veterinary Preventive Medicine, Ohio State University

73) Jillan Sackett, MD, MS self-employed affiliated: Climate Psychiatric Alliance

74) Natalie Sampson, Ph.D., MPH Asst. Professor of Public Health U. Michigan, Dearborn

75) Tamara Estes Savage, Ph.D., MSW. Asst. Professor, Dept. Social Work

University of North Carolina, Pembroke

76) Michael Schmeltz, DrPH, MS Asst. Professor California State University, East Bay

77) Peter Schnall Professor Emeritus University of California, Irvine, COEH

78) Rose M. Schneider, BSN, MPH Sr. Health and Climate Change Advisor

Health Systems Management

79) Amy J. Schulz, Ph.D., MPH, Professor School of Public Health, University of Michigan

80) Katherine Schwartz, MS, MPH adjunct lecturer NY College of Medicine and Lehman College

81) Ellen Shaffer, Ph.D., MPH, Assistant Adjunct Professor University of California Medical Center, San Francisco

82) Brett Sheppard Project Manager, Center for Health Promotion&Disease Prevention

University of North Carolina at Chapel Hill

83) Craig Slatin, Sc.D., MPH Professor Emeritus Dept. Public Health, U. Mass., Lowell

84) Cindie Slightam Researcher Virginia Healthcare System

85) Kenneth Smith Distinguished Professor University of Utah

86) Joseph B. Stanford MD, MSPH Professor, Vice-Chair Dept. Family and Preventive Medicine, University of Utah

87) Patrice Sutton, MPH Research Scientist University of California, San Francisco

88) Mark Swoiskin, MD Associate Clinical Professor Dept of Psychiatry, University of California, San Francisco

89) Michelle Teegarden, MPH

90) George Thurston Professor of Environmental Medicine and Population Health

New York University School of Medicine

91) Theodora Tsongas, Ph.D., MS environmental health scientist/epidemiologist

Member of Environmental Health Work Group of Oregon Physicians for Social Responsibility

92) James VanDerslice, Ph.D. Associate Professor, Associate Chief

Division of Public Health, Dept. of Family and Preventive Medicine, University of Utah

94) Leon F. Vinci, DHA, DAAS CEO/President Health Promotions Consultants

95) Adrienne Wald, EdD, MBA, RN, CNE, MCHES. Associate Professor, Mercy College (New Rochelle) School of Health and Natural Sciences

96) Deborah Wallace, Ph.D. retired, Sr. Project Leader retired from Consumers Union

97) Robert G. Wallace, Ph.D visiting scholar Inst. For Global Studies, University of Minnesota

98) Rodrick Wallace, Ph.D. Research Scientist Div. of Epidemiology, NYS Psychiatric Inst.

99) Nina Wallerstein, Ph.D. Professor and Director Center for Participatory Research, College of Population Health, University of New Mexico

100) Lucy Weinstein, MD, MPH Asst. Clinical Professor Dept. Preventative Medicine

State University of New York, Stony Brook School of Medicine

101) Ellen M. Wells, MD Associate Professor School of Health Sciences, Purdue University

102) Claire Wendland, MD, PHD Professor University of Wisconsin, Madison

103) Kathryn Wouk, Ph.D. Postdoctoral Research Fellow University of North Carolina at Chapel Hill

104) Cathleen Zick Associate Dean College of Social and Behavioral Science University of Utah

*for identification only and not reflecting institutional policy or stance

ID: EPA-HQ-OA-2018-0259-11179
Tracking Number: 1k4-9gl9-9gif
Document Information
Date Posted:
May 13, 2020
RIN:
2080-AA14
This agency received 104 duplicate or significantly similar comments.

See PDF original here: https://www.regulations.gov/document?D=EPA-HQ-OA-2018-0259-11179

Information-comments from the earlier comment period two years ago:
https://miningawareness.wordpress.com/2018/05/25/trump-pruitts-epa-announces-extended-comment-period-and-public-hearing-on-so-called-transparency-rule/
https://miningawareness.wordpress.com/2018/05/20/nearly-1000-scientists-tell-trump-pruitt-epa-dont-restrict-epas-ability-to-rely-on-science-comment-by-may-30th/
https://miningawareness.wordpress.com/2018/08/16/trump-epa-proposal-re-dose-response-analysis-is-inappropriate-and-not-scientifically-based-say-epidemiologists-comment-by-thursday-night-1159-pm-eastern-time/
https://miningawareness.wordpress.com/2018/08/15/national-tribal-air-association-comment-opposing-proposed-us-epa-rule-comment-deadline-thursday-night-1159-pm-eastern-time/
https://miningawareness.wordpress.com/2018/08/15/the-president-of-harvard-university-letter-opposing-proposed-us-epa-rule-comment-deadline-thursday-night-1159-pm-eastern-time/
https://miningawareness.wordpress.com/2018/08/11/trump-epa-cost-benefit-analysis-pre-rulemaking-comment-deadline-is-monday-august-13th-11-59-pm-eastern/
https://miningawareness.wordpress.com/2018/05/08/new-york-attorney-general-tries-to-protect-people-environment-from-100-fold-increase-in-radiation-and-other-toxic-dangers-gets-accused-of-abuse/