We continue to rattle the EPA.
Over the weekend and by chance, I came across a new EPA web page on its human experiments. Our charges that EPA secretly hired the NAS to whitewash its illegal human experiments program apparently forced the agency to put up this page on August 23, 2016 — the day before our August 24, 2016 testimony before the National Academy of Sciences about EPA’s illegal experiments. It’s a doozy. Here are some highlights.
Here’s the home page for its human testing. Pretty boring EXCEPT that EPA has now apparently formed a single office to administer its (illegal) human testing. When we first exposed EPA’s experiments, the illegal air quality experiments were a rogue and basically secret operation, entirely separate and apart from the more public Human Studies Review Board which was limited to review of human studies involving pesticides.
The next page discusses a key problem with the EPA human experiments — they are not systematic in nature and so do not constitute “research” under federal regulations. Because they do not qualify as research they are prohibited. This was pointed out to the NAS Committee in Milloy slides 61-66.
In the page below, the last paragraph is of most interest — it describes why EPA is doing its human experiments with particulate matter (PM). At face value, EAP conduct teh experiments so it can detect health effects among its human guinea pigs that it can then extrapolate to death. The problem for EPA, here, is that the agency has repeatedly stated thant any exposure can cause death. EPA administrartor Jackson has also testified to Congress that: “Particulate matter causes premature death. It doesn’t make you sick. It’s directly causal to dying sooner than you should.” See Milloy slides 8-18.
Next, EPA tries to more directly address why it conduct human experiments. It admits the weakness of its epidemiologic studies that “rely heavily on statistcial inferences and assumptions” — i.e., guesswork. Milloy slides 52-55 explain more clearly why EPA does these experiments — i.e., since the epidemiology and animal toxicology fail to link PM inhalation to death, EPA needs to cause harm to its human guinea pigs so that the effects can be extrapolated to death.
The next page does a laughable job of explaining how EPA protects its human guinea pigs. Yes, rules for the protection of test subjects exist — but if you don’t follow them then they don’t mean much do they? EPA says that any exposure to PM can kill within hours. If true, such an experiment is flatly illegal. Compounding the illegality is EPA failure to inform study subjects that it has determined that PM could kill them within hours of the experiment.
This next page is notable for in it EPA touts its ban on experimenting with children. As explained to the National Academy of Sciences, in between the time this ban was proposed and the EPA finalized it, the EPA funded USC/UCLA researchers to spray high doses of diesel exhaust up the noses of children as young as 10 years of age. See Milloy testimony slides 26-33.
Next, EPA touts its 14-level approval process for the experiments, including an Institutional Review Board. In the case of EPA’s PM experiments, no IRB was ever informed that EPA had determined that any non-zero exposure to PM could kill within hours. EPA can have all the review levels it wants, but everyone is being misinformed, then the number of review levels really doesn’t matter.
Now the EPA gets into the NAS Committee review of its human experiments. EPA points out that “the NAS is not investigating EPA research.” That is, or hopefully was true — because the EPA hired the NAS to whitewash, not to examine its human experiments. JunkScience found out about the covert process and opened it up to sunlight.
Next, EPA addresses the EPA Office of Inspector General report that forced it to hire the NAS to do the whitewash. The IG report found that EPA failed to obtain informed consent from the human guinea pigs by failing to disclose to them the risk of death from the experiment. Oddly, though, the IG report never addressed the more fundamental issue of whether the experiments were even legal in the first place — no, EPA cannot try to hurt people in order to advance its regulatory agenda.
Despite EPA claims to the contrary, the Inspector General report validated our charges against EPA and forced EPA to seek the NAS whitewash.
Here’s the really big whopper on this page. EPA poses the question whether it is ethical to expose people to low levels of carcinogens. But cancer risk is not the issue. EPA says PM kills and any exposure to PM can kill within hours of inhalation. Diesel exhaust, in particular, is 95% PM. So the actual question is: Is it ethical (or even legal) to expose people to a substance that EPA has determined can kill them virtually instantaneously?
Finally, EPA notes that no one has ever been permanently harmed by its experiments. This is only part of the truth. The entire truth is no one has even been transiently harmed by EPA’s experiments despite very high levels of PM exposure. In the end, these experiments debunk rather han support EPA’s stringent PM regulations.