30 May Golden Rule Project Manager Helen Jaccard Comments on the EPA’s New Proposed Rule

I oppose EPA’s proposed rule, Strengthening Transparency in Regulatory Science. There are many cases in which it would be legally complicated or outright unethical for researchers to make their data fully transparent. Without a signed release by every participant, most epidemiological studies’ data cannot be made public!  This rule would invalidate ALMOST ALL of the research needed to correlate contamination to health effects.

Furthermore, increasing transparency alone is not sufficient to ensure adequate protection of the public.  Radiation protections do not cover all of the various nuclides that are contaminating public and tribal water and are not strict enough considering that children and women are affected up to seven times more than the standard 35-year old white man.

EPA must continue to use at least the standards that are now in place for radiation – the linear, no threshold model for cancer risk.  The National Academy of Sciences determined a decade ago that there is no safe dose of radiation.

– Helen Jaccard, VFP Golden Rule Project Manager