Medical Advocates for Healthy Air submitted comments in response to the Environmental Protection Agency’s (EPA) request for comments on the proposed “Strengthening Transparency in Regulatory Science” rule (83 FR 18768). If implemented the proposed rule would:
- Exclude critical epidemiological and clinical studies derived from human databases
- Impede the development and utilization of new science
- Exclude historical studies as the data banks may not be currently available or constrained by prior disclosure agreements
- Be duplicative as there is already an external review committee called the Clean Air Science Advisory Committee that provides a diverse, independent science peer review of all the considered science.
While transparency is a commendable goal in the development of any policy, it must be applied in a manner that respects individual privacy rights while in pursuit of credible and honest decisions. MAHA is a strong supporter of EPA’s mission to protect human health and the environment utilizing the best available and defensible science as the foundation of sound policy. As such, MAHA sees a direct legal and moral conflict in the proposed transparency rule in its current iteration if the Agency is to pursue its mandated mission.
Fifty two MAHA members added their names to the comments. You can read the full comments submitted by MAHA here.