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Policy Summary
The Trump administration has proposed a new rule that would limit the kinds of research studies deemed credible and usable by the EPA for analysis of existing and proposed legislation and environmental practice. The administration is proposing that when the EPA is evaluating scientific research for the purposes of writing new legislation or revising existing legislation, the agency is to “give preference” to those studies that make all their underlying data available to the public. Though transparency is of course important, this proposal concerns many, because many significant and credible research studies rely on the personal data of individuals (such as health records), which are only made available by individuals to research scientists under the condition that their personal information will remain confidential. For example, a 1993 study by Harvard University called the Six Cities Study, found a link between air pollution and premature deaths. This study used the personal health records of its study subjects as part of its data analysis, including confirming that premature deaths weren’t just simply a result of other underlying illnesses the subjects may have already had. However, that data from the health records is confidential to those individuals and, under law, is not allowed to be released to the public. Many of the study participants were only persuaded to provide personal information, because they were ensured that their personal information would remain confidential. The Trump administration is essentially saying that those studies should no longer be considered so credible and thus, either shouldn’t be used in EPA analysis, or shouldn’t carry as much weight and influence as any other study that happens to have only publicly available data.

This proposal is justified by the administration under the guise that it is making government research more transparent, but in reality, it is simply limiting the research that is available for analyzing many important environmental issues, including research that currently supports legislations that the administration has been unsuccessfully trying to roll back. Andrew R. Wheeler, the current Administrator of the EPA says the new rule “will ensure that all pivotal studies underpinning significant regulatory actions at the EPA, regardless of their source, are available for transparent review by qualified scientists” (Friedman). Contrary to Wheeler’s opinion, this comes off to many as simply a strategy to make credible, and possibly damaging, research un-usable in the analyses of many environmental issues. Lisa Friedman, of the New York Times, writes that the American Association for the Advancement of Science feels “The administration’s real goal was to raise suspicions about the bedrock studies that helped establish modern regulations governing clean air and water” (Friedman). And, that this is just another effort “to dilute scientific research, especially on climate change and air pollution, which has underpinned rules that the fossil fuel industry calls burdensome” (Friedman).

The scientific community has criticized the proposal since it was first initiated in 2018. At first, the new proposal mandated that only studies with full public data would be allowed for analysis by the EPA, but the administration recently revised that proposal to say “give preference” to studies that have made all of their underlying data public. Still, the proposal is being criticized by environmental activists and leaders from the Obama administration as making it “easier for the EPA to weaken or repeal existing health regulations, because studies that had previously been used to show the benefits might now be discarded or assigned less importance” (Friedman). Back in January, even an Advisory Panel of scientists appointed by Trump and Wheeler, criticized the new proposal, stating that the EPA has not “fully identified” what the health problem is that this rule is supposedly addressing. What health issue is the EPA trying to solve by implementing this proposal?

Gina McCarthy, Head of the EPA under the Obama administration, is criticizing the current agency leaders for moving forward with this new rule while our country is in the middle of the Covid-19 health crisis. She says, “Now is not the time to play games with critical medical research that underpins every rule designed to protect us from harmful pollution in our air and in our water” (Friedman). Andrew Rosenberg, Director of the Union of Concerned Scientists at the Center for Science and Democracy, said of the proposal, “Benchmark science like Harvard’s Six Cities air pollution study might soon be deemed inadmissible” (Friedman). Rosenberg continued, “They’re putting in non-scientific criteria to decide what science the agency can use.” “Now the most important thing is whether the data is public, not the strength of the scientific evidence” (Friedman). The proposal essentially gives the EPA Administrator the discretion to decide whether or not to use a study that has not made all its personnel and other data public. According to Rosenberg, this would essentially “take scientific decision-making out of the hands of scientists and hand it to a politically appointed administrator” (Friedman). In short, implementing this proposal would mean that at the United States Environmental Protection Agency, scientists no longer decide what the most credible data is, now a politician does.

Resistance Resources:

  • The American Association for the Advancement of Science
    • The world’s largest general scientific society, and an American international non-profit organization with the stated goals of promoting cooperation among scientists, defending scientific freedom, encouraging scientific responsibility, and supporting scientific education and science outreach for the betterment of all humanity. Publisher of the scientific journal Science.
    • https://www.aaas.org/
  • The Union of Concerned Scientists
    • Nonprofit science advocacy organization. Founded in 1969 to “initiate a critical and continuing examination of governmental policy in areas where science and technology are of actual or potential significance.”
    • https://ucsusa.org/
  • The National Association of Pediatric Nurse Practitioners
    • Dedicated since 1973 to “improving the quality of health care for infants, children and adolescents, and to advancing the APRN’s role in providing that care.”
    • https://www.napnap.org/
      • “Supporting academic health sciences libraries and directors in advancing the patient care, research, education, and community service missions of academic health centers through visionary executive leadership and expertise in health information, scholarly communication, and knowledge management.”
      • https://www.aahsl.org/The Association of Academic Health Science LibrariesPhoto by Hans Reniers
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