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DOULL & WADDELL: Balancing policy with science
Proposal to ban dioxin in nature is misguided
As we move to make our world safer from chemi- cals, it is criti- cal that we not use politics to determine environmental policy. The Environmental Protection Agency (EPA) must maintain a clear commitment to reviewing all relevant science in the determination of policy, not just the science that leads to a preconceived conclusion. Major policy changes in this space should produce health benefits, and those benefits must be communicated to the public.
Unfortunately, in the case of the proposed regulation of dioxin announced earlier this year, it is clear to those of us who have been engaged for many years in environmental toxicology that the EPA has stepped beyond what science can actually prove. In fact, the EPA is out of sync with highly respected scientific bodies, including the National Academy of Sciences (NAS), the exceptionally careful World Health Organization and science-based regulatory bodies in Great Britain, Japan and other countries.
Last month, the EPA responded to concerns the NAS had raised about a previous proposal from the agency. The EPA proposed new standards to regulate a group of chemicals called dioxins. If enacted, those standards would set America on a course for "Mission Impossible." It's likely that not even Mother Nature could meet the proposed new standards.
Moreover, the EPA is getting ahead of itself in its zeal to regulate a substance that is more than 90 percent lower in the environment today than it was 25 years ago. In January, the EPA also issued a separate proposal for Preliminary Remediation Goals for soil. If these new soil goals go into effect, they will force local governments to undertake vastly expensive cleanup efforts.
The problem with this approach is that the EPA is premature in setting soil standards when it has not even set standards for human exposure to dioxin. As a result of the process the EPA has set into motion based on narrowly selected science, we are being led to believe, contrary to a large body of studies, that any exposure to dioxin is harmful. Using this logic, the vast majority of us are being exposed to too much dioxin through our food, and our health is as risk because of it.
Unfortunately, without balancing the complete body of scientific evidence with clear policy goals, we are setting a precedent that has potential for sweeping negative consequences. The EPA is suggesting that any suspicious chemical - even if naturally occurring, like dioxins - can pose substantial harm to humans. In the case of dioxin, the main sources today are forest fires, backyard trash fires, indoor wood burning and even volcanic eruptions.
That is why the highly respected NAS asked the EPA to explain why it would rely so heavily on the idea of no threshold for dioxins. In its proposed regulation, based on a linear no-threshold perspective, the EPA is setting a standard that just a few molecules can cause harm. It is saying de facto that eliminating a naturally occurring substance is an optimal policy goal.
Having served on NAS panels, been leaders in the science of toxicology and written toxicology textbooks used in academic institutions, we say it is not clear to us that the EPA has offered a workable solution incorporating sound science that is clearly protective of public health. These new regulations call into question the body of scientific studies we know about, change the course of how we will answer questions of potential harm in ways that are not validated by science and do so without any explanation of what is to be gained for public health.
During the public-comment period on the EPA proposal, we have a chance to make our voices heard and hopefully prevent the EPA from taking misguided action. Not to do so will lead to billions of dollars of wasted spending with no clear understanding of what cancer or other diseases we are actually preventing.
The public needs to pay close attention to the planned regulatory change, and we call on our fellow scientists to review and weigh in on the EPA's proposal so we can make the best decisions to protect the public's health.
John Doull, M.D., Ph.D., is professor emeritus at the Department of Pharmacology and Toxicology of the University of Kansas Medical Center. William J. Waddell, M.D., is chairman emeritus at the Department of Pharmacology and Toxicology of the University of Louisville School of Medicine.
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