A revealing e-mail exchange involving Linda Birnbaum, the director of the National Institute for Environmental Health Sciences and National Toxicology Program.
The focus of this story is e-mail commentary from Birnbaum on my recent Washington Times commentary, EPA Lied — Nobody Died about the National Academy of Sciences’ whitewash of EPA illegal human experiments.
A former federal scientist had forwarded my column to about 200 people, including Birnbaum. She responded as follows:
Here’s the line-by-line takedown of Birnbaum’s response to my commentary:
LB: I believe the EPA experiments were NOT unethical and provided a great deal of information in setting the regulations re to air pollution.
[SM: Her bald-face belief aside, EPA has never used the information in the PM2.5 human experiments in setting air standards. Never. As far back as 2004, EPA determined that there is no safe level of inhalation of PM2.5 and that any inhalation could be lethal within hours. Yet the experiments have continued and EPA would like to continue doing them. If there is no safe level how can EPA ethically/legally conduct the experiments and what would be the point anyway?]
LB: The Clean Air Act requires that the regulations protect the most sensitive members of the population –– not the average.
[SM: The Clean Air Act requires that air standards be protective of public health with a margin of safety — there is no mention of/allusion to “most sensitive members of the population.” But entertaining her “most sensitive” fantasy nonetheless, we know that PM2.5 won’t kill even the most sensitive member of the population. How do we know? First, how do these people survive on a day-to-day basis since PM2.5 inhalation is unavoidable. Next, the sickest person on this planet will not be killed by smoking a cigarette which delivers PM2.5 at a rate 25 times greater than the very foulest air ever inhaled in a Chinese city — incidentally where there are no reported (vs. statistically imagined) deaths from air pollution. Ever seen someone on oxygen smoking? These people often smoke for years. The greatest risk to them is setting the oxygen tank on fire. The reality is PM2.5 is innocuous]
LB: And, what is clear from a wealth of clinical and epidemiological studies, is that our current regulatory limits are not protective of the most sensitive.
[SM: EPA admitted in litigation with me that its epidemiologic studies show nothing — that’s why they do the human experiments, to try to make something clinically adverse happen. But EPA researchers admit that no one has ever been harmed by its clinical experiments. Given that animal toxicology and a variety of real-world examples also exonerate PM2.5 from claims of killing people, there is ZERO basis for claiming that PM2.5 kills.]
LB: WHO estimates that nearly 7 million people die every year from air pollution, of whom approximately 3 million are due to outdoor air pollution, the remainder being due to indoor air.
[SM: The WHO claim is is entirely boot-strapped from EPA’s faulty/fraudulent claims.]
LB: Air pollution has a wealth of impacts – pulmonary, cardiovascular, neurological, metabolic, and maybe more. There may be no “safe” level of air pollution. And we would all breathe easier as levels come, and stay, down.
[SM: Modern air quality, insofar as it is impacted by manmade emissions, causes no discernible harm of any sort to anyone. While there were at least three 20th century incidents of lethal air pollution (Meuse Valley, Donora, London), we know (read my book “Scare Pollution”) that they were caused by temperature inversions temporarily trapping acidic aerosols, not inocuous PM2.5.]
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Summary
So Birnbaum believes the EPA experiments are “ethical” but that “There may be no safe level of air pollution.”
Of course, if “there may be no safe level of air pollution” then it is axiomatically unethical/illegal to experiment with air pollution (especially high levels of it) on the (supposedly) “most sensitive members of the population” — such as the elderly, young and sick.
This logical box has exposed EPA’s perfidy and Birnbaum’s absolute intellectual and/or moral bankruptcy in trying to defend the EPA.
You read my earlier clash with Birnbaum over the EPA’s human experiments in Scare Pollution: Why and How to Fix the EPA.
If the experiments were conducted to protect the most sensitive then why not conduct the experiments on the most sensitive? I don’t recall any mention of pre selection for sensitivity when selecting uninformed volunteers.
Following Ilma’s post above: Birnbaum should be indicted as an accessory.
That claim about “most sensitive members” is suspiciously analogous to the often-heard claim that the best attainable healthcare is everyone’s right. I believe I have seen that chiseled in stone in several places.
With the cost of best attainable healthcare tending to infinity, these ideas have comfortable room for growth.
Thanks for addressing ‘most sensitive members,’ Steve.
A calamitous national policy had it been true.
If Birnbaum believed that even the smallest dose of pm2.5 would kill, then performing the experiments knowing this must surely count as attempted murder/manslaughter?
The most outstanding item [among many] reported in ‘Scare Pollution’ was for me the fact that the investigation, 86 years ago, of the Meuse Valley incident ruled out PM, after careful consideration, as a causal factor…..
IMHO, junk science was founded in the non-sequiturs bandied about early in the last century about special relativity………
eg ‘clock A runs faster than clock B and clock B runs faster than clock A’ ……
‘every point-of -view is just as valid as every other point-of-view’……….
For over a century uncritical/ignorant people have been trying to reinvent the wheel to the annoyance and frustration of those who think sanely and logically.
The main issue with the human experiments on PM inhalation is the two directly contradictory claims made:
1. [Public] ‘PM is a health threat at all concentrations >0’ ;
2. [Private, to volunteer subjects] ‘You may experience minor transient discomfort from inhaling diesel fumes’
From which it follows that either:
3. These ‘scientists’ knew that they were making a false statement to the public thereby causing unnecessary fear and distress among millions of people, or;
4. They conducted ‘medical experiments’ in the ‘Mengelean tradition’, banned outright for the past 70 years.
Birnbaum’s responses are classic bureaucratic doublespeak by someone who feels compelled to respond to criticism, but really pretty much lacks understanding of the facts underlying the criticism. So she makes up sentences.
I love her logic that (a) there is no safe limit to PM2.5 exposure, but (b) it is not illegal/unethical/immoral to expose countless people (who apparently are not warned that any amount of exposure is unsafe) to various unlimited amounts in an apparent “study” to find out how sick or dead they will get.
Of course there is a ‘safe’ exposure to sarin. One molecule, as an extreme example, will not kill. Toxicity is high — the lethal dose in humans may be as low as 0.01 mg/kg. But you will still survive a very low exposure. https://pubchem.ncbi.nlm.nih.gov/compound/sarin#section=Safety-and-Hazards
In contrast, the EPA says there is no safe exposure to PM2.5 — i.e., even one molecule can kill.
We know that there is no safe limit to sarin gas exposure, but adverse effects can be ascertained by human testing.
Warren, do you have special information different to what was asserted above? Didn’t the EPA state that there is no safe limit to PM 2.5 like it says above? Do you know what that means? It means that it is not the case that adverse effects can be ascertained by human testing without serious or permanent harm. Just stating something does not make it true!
1) No one has been harmed. But adverse effects can be ascertained by human testing without serious or permanent harm.
2) It would be unethical NOT to perform the testing required to determine what can be done to improve human health.