Any time you fill your car's gas tank and can smell gasoline, you're inhaling some small amount of benzene. Fortunately, inhaling some small amount of benzene on an occasional basis is not deadly, nor does it necessarily have long-term health risks. But inhaling a lot of benzene on a regular basis will kill you, as benzene is a known human carcinogen.
How do we know this and how do we know how much benzene can be inhaled without any negative health effects? The answer, it turns out, is that medical researchers and scientists working for the U.S. EPA have been reviewing medical records and academic dose/response studies to gain insight into how much exposure is acceptable and how much is "too much." These studies and the EPA's conclusions are summarized in peer-reviewed papers and publications which are widely discussed and frequently questioned and criticized, and eventually the data is used to come up with estimates of acceptable exposure concentrations. The EPA keeps an archive of the findings and the derived health-risk factors on line as a public service and to promote good science and sound decision making with regard to chemical exposures.
In the last 10 or so years of my consulting career, I increasingly had to use the results of these studies and their derived acceptable exposure concentrations to calculate clean-up goals for environmental restoration and pollution abatement projects. These calculations involve a complex synthesis of chemistry, biology, and hydrology, as well as conceptual models of how the population might become exposed to the polluting chemicals. It's difficult stuff, and it literally took me decades of practice and experience to get to the point where I could make meaningful recommendations for clean-up goals, and to help the parties responsible for the remediation and the government regulators overseeing the projects come to an agreement as to how clean "clean" should be.
Without the medical records and academic dose/response studies, our understanding of the health risks would be severely impaired, and the decisions and recommendations on clean-up goals would become meaningless. They are the foundational basis for the decision making, and help governments understand if, say, tighter controls are needed at the gas pump to limit cancer deaths associated with exposure to benzene, or inversely, if money is being wasted on unnecessary controls where chemical exposure is not unacceptable.
Enter the Trump administration. Since these studies, more often than not, suggest greater risks than previously known, they often require businesses and industry to invest more money into pollution control equipment and measures. So the EPA has proposed new rules that will limit the use of medical records and dose/response studies in determining acceptable chemical exposure concentrations.
EPA's stated reason for the limitations is "transparency." While the studies and conclusions, as well as the peer-reviewed summaries and determinations of the acceptable chemical-specific exposure concentrations, are public, much of the specific medical data are confidential, as they're derived from doctor-patient records. The Trump EPA is now stating that's not "transparent" enough, and any conclusions that rely on studies based on confidential medical records cannot be used to set standards or regulate industry.
The result of this is that a great many regulations on the amount of pollutants an industry can emit to the atmosphere, can dump into a river or lake, or allow the public to be exposed to, may be struck down when they come up for renewal. The proposed new "transparency" bill is also retroactive, which means some regulations may be overturned even before their renewal dates.
This will lower the cost of environmental compliance for industry, but at the expense of the health and longevity of the American public. In effect, the burden of the cost of compliance will be shifted from industry's bottom line to our medical expenses and we'll be literally picking up the tab with our lives.
No one has ever accused the scientific community of falsifying the confidential medical records in order to justify more stringent pollution limits, and there are no known cases of this occurring. The need for "transparency" is just industry's alibi for discrediting the regulations, and Trump's EPA is playing along. Need we point out that this rule was first proposed by discredited former EPA Administrator Scott Pruitt, who as the Attorney General of Oklahoma had previously sued the Agency on numerous occasions for "over-enforcement" before Trump nominated him for the head position at EPA?
This rule, if passed, would be a terrible thing for the health of this nation, and the damage caused may take years to correct, even if a new Administration reverses the rule in 2021. Fortunately, the rule, after it is published in the Federal Register, will have a 30-day public comment period. While the EPA can choose to ignore comments or rationalize them away (i.e., "We considered this concern but decided it did not have merit"), it's our best and only shot at preventing this rollback of our protections. After publication, comments are to be mailed to:
U.S. Environmental Protection AgencyI urge everyone to look into this matter themselves, and to write EPA to tell them "No."
EPA Docket Center, Office of Research and Development Docket
Mail Code 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20004
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