Dean Goldman Testifies About Effects of Proposed EPA Rule

Members of the Department of Environmental and Occupational Health (EOH) at GW’s Milken Institute School of Public Health are regularly called to testify at federal government hearings. Michael and Lori Milken Dean Lynn R. Goldman, MD, MS, MPH recently testified about the impacts of a proposed U.S. Environmental Protection Agency (EPA) rule to the agency’s Science Advisory Board.

The EPA Science Advisory Board was created by the U.S. Congress 40 years ago to review the quality and relevance of the scientific and technical information being used by the EPA or proposed as the basis of agency regulations. The Dean responded to a recent memo recommending that the Science Advisory Board review the agency’s proposed rule, “Strengthening Transparency in Regulatory Science.”

The rule would require that the underlying data for all scientific studies used by EPA to assess the risk to human health posed by exposure to varying doses of environmental chemicals be publicly available.  This requirement would sharply limit the number of studies available for consideration because much research relies on confidential health data from study subjects.

“By restricting access to data and causing delays in EPA processes, this proposal threatens EPA’s ability to protect public health and the environment,” the Dean said in her testimony. “The proposed rule is a dramatic departure from how the EPA and other U.S. regulatory agencies, and similar agencies internationally, develop dose response assessments in the context of regulatory decisions.”

The Dean’s broad and deep public policy and academic experience includes serving from 1993 to 1998 as the EPA’s Assistant Administrator for what is now called the Office of Chemical Safety and Pollution Prevention. She helped craft the Food Protection Act passed by Congress in 1996, the first national environmental law to explicitly require measures to protect children from pesticides. Prior to joining the Milken Institute School of Public Health in 2010, Dean Goldman spent nearly a dozen years as a professor of Environmental Health Sciences at the Johns Hopkins Bloomberg School of Public Health.

In her testimony, the Dean observed that the rule “suffers from a lack of involvement of the scientific community” and that no clear justification exists for why the rule is needed.  She also pointed out a number of other adverse consequences, including that the agency would risk disclosure of personal information from people volunteering for research studies.

The Dean concluded by urging the EPA Science Advisory Board to recommend that the Administrator not use “the agency’s regulatory authority to prescribe specific risk assessment processes. Period.”