The Environmental Protection Agency (EPA) recently invited testimony on the proposed Strengthening Transparency in Regulatory Science rule. The rule, aiming to establish a clear policy concerning the use of dose-response data and models that underlie regulatory science would, in effect, eliminate all studies based on non-publicly available data from consideration in constructing environmental policy that can affect health. For example, this would preclude from consideration any study involving sensitive health data that cannot be made public for ethical concerns, without accounting for the context under which the data is kept private.
Dr. Elizabeth Geltman, a professor in the Department of Health Policy and Management at the CUNY Graduate School of Public Health & Health Policy (CUNY SPH) and an expert on environmental health policy, appeared before the EPA to give testimony on the proposal.
Geltman stated that despite its goal of establishing transparency about what scientific evidence is considered in the process of creating environmental regulations, in practice, the new rule just creates new regulatory hurdles by discounting and precluding consideration of long-standing, established scientific practice. Geltman warns that rather than promote the transparency of the scientific information used, the rule will obscure the democratic process, slow the pace of science and progress and potentially prevent important health data from being considered by the EPA in outlining environmental policy.
Geltman points out that many studies require people who are study subjects to share very personal information, often on the legal or ethical condition that the private medical information provided will be protected from public view.
Arguing that the EPA has presented no scientific reason to prevent the use of human health studies simply because the underlying medical records are not available for public inspection and review, Geltman calls for the EPA to allow consideration of all available scientific data pertinent to a proposed environmental rule or regulation, including randomly controlled human health trials and other epidemiological studies, in order for policy makers to be able to make informed decisions on environmental regulations that may affect health.
Geltman has over 30 years of experience working on EPA regulated matters and has authored 17 books on environmental and natural resources policy.