bureaucracy, cancer slope factors, clean air, clean water, DEQ, environment, EPA, Human health, ineffective bureaucracy, inhalation unit risk, National Ambient Air Quality Standards, National Ambient Water Quality Criteria, OHA, Oregon Department of Environmental Quality, Oregon Health Authority, reference concentrations, reference doses, regulations, regulatory science, Trump EPA, US EPA
Comment by May 18th on the Environmental Protection Agency (EPA) Proposed Rule, which is misnamed “Strengthening Transparency in Regulatory Science”. Related information, Open Docket Folder and comment here: https://www.regulations.gov/docket?D=EPA-HQ-OA-2018-0259 Comments can be anonymous.
Strengthening Transparency in Regulatory Science Proposed Rule Comments of the Oregon Health Authority and Oregon Department of Environmental Quality April 16, 2020:
Mr. Andrew Wheeler Acting Administrator
U.S. Environmental Protection Agency Washington, D.C.
RE: Strengthening Transparency in Regulatory Science Docket ID No. EPA—HQ—OA-2018-0259 [FRL-10004-72-ORD] — Supplemental Notice of Proposed Rulemaking 03/03/2020
Dear Mr. Wheeler:
The Oregon Health Authority (OHA) and Oregon Department of Environmental Quality (DEQ) offer the following comment on proposed Strengthening Transparency in Regulatory Science Rule by the US Environmental Protection Agency (EPA) (40 CFR Part 30) (EPA—HQ—OA-2018-0259; FRL-10004-72— ORD). This rule is described as a measure to ensure that data underlying scientific studies that are pivotal to regulatory actions are “publicly available in a manner sufficient for independent validation.”
As agencies charged with protecting the environment and public health of all Oregonians, OHA and DEQ use EPA standards and guidelines such as National Ambient Air Quality Standards, National Ambient Water Quality Criteria, reference concentrations, reference doses, cancer slope factors, and inhalation unit risk values daily. OHA and DEQ rely on EPA to provide guidance and standards based on the best available science that considers the overall weight of scientific evidence for protection of human health and the environment.
In previous comments submitted August 16,2018, OHA and DEQ encouraged the EPA not to adopt the proposed “Strengthening Transparency in Regulatory Science” rules and explained the rationale for opposing the rule.
In response to public comments, the EPA is proposing updates to the proposed rule. OHA and DEQ find that the proposed updates do not adequately address our concerns. In fact, they broaden the scope of information and study types that would be adversely affected by this rule.
As we stated in our previous comments, increasing transparency in science is an important goal that EPA could more productively support by funding and creating data-sharing Infrastructure that researchers from all sectors can use. The approaches in the proposed rule are too far downstream in the scientific process; unduly prescriptive; likely to increase costs and reduce supply of useful science; and likely to introduce bias and inefficiency in EPA’s process of evaluating and developing regulatory science.
In response to public comments, the EPA has embraced the concept of tiered access to data that will require data repositories. The establishment of such data repositories is being actively explored by several agencies, and the US Centers for Disease Control and Prevention has already established such a repository with which the EPA Is conducting a pilot study. The establishment of such data repositories are consistent with and complement the different open data access policies that have been making government-generated data publicly available for the past five years. Further, the government agencies that sponsor extramural research are already moving to integrate those programs into their open data access policies. Similar movements to ensure open data access are underway in Europe and elsewhere. Thus, the Strengthening Transparency in Regulatory Science Rule will create an ineffective bureaucracy that will have minimal impact on strengthening transparency in regulatory science and will only serve to curtail EPA’s ability to respond to crises such as the current COVID-19 pandemic. As such, DEQ and OHA strongly urge the EPA to withdraw the proposed rule.
Lillian Shirley, BSN, MPH, MPA Director, Public Health Division Oregon Health Authority
Richard M. Whitman Director
Oregon Department of Environmental Quality
Tracking Number: 1k2-94vu-ikeb”
Emphasis our own. Original here: https://www.regulations.gov/document?D=EPA-HQ-OA-2018-0259-6359
Information-comments from the earlier comment period two years ago: