EPA's Proposed Cancer Risk Assessment Guidelines

A Junk Scientist's Dream Come True

http://www.epa.gov/ORD/WebPubs/carcinogen



At long last, the wait is over. After almost nine years, the U.S. Environmental Protection Agency has finally proposed to update its cancer risk assessment guidelines. After reviewing them, I think I would have waited a lot longer, perhaps forever. If you're a fan of junk science, though, you couldn't ask for more.

EPA's cancer risk guidelines were first issued in 1976 and updated in 1986. The 1986 guidelines were viewed so dimly, however, that efforts to revise them began as early as 1988. Since then, the public has been continually teased by rumors about the "imminent" release of new and improved guidelines. Now, new proposed guidelines are out. But, for one major reason, they are a giant step in the wrong direction.

As rightfully acknowledged by EPA, potentially the most valuable tool to the risk assessor is epidemiology, the study of distributions and causes of disease in actual human populations. In short, epidemiology is the study of real people in the real world.

However, there is good epidemiology and there is bad epidemiology. To help distinguish good from bad, criteria have been developed and employed. For example, epidemiologic risk estimates are more credible when they are large and precise. Exposures of concern should precede the onset of diseases by biologically reasonable amounts of time. Observed risks should make sense in terms of biological knowledge. Risks should be observed for similar exposures in different populations in different studies. There should be a dose-response relationship where the greater the doses the greater the observed risks.

Of critical importance among these criteria, is the requirement that epidemiologic results be statistically significant. That is, and for the sake of simplicity, there should be some level of confidence, usually 95 percent, that observed study results did not occur by luck or chance. Study results that are not statistically significant, are deemed to be a fluke and are not suitable for concluding that a risk exists.

The traditional requirement of statistical significance has long been the Achilles heel of epidemiologists and, hence, risk assessors. Because of statistical significance, epidemiologists have not been able to convincingly associate electromagnetic fields, dioxin, environmental tobacco smoke, dietary pesticide residues, and hazardous waste sites, to name a few, with cancer because the results of their epidemiologic studies often have not been statistically significant.

But if EPA has its way, this problem will be no more. Answering the prayers of many epidemiologists and risk assessors, EPA, through its proposed cancer risk assessment guidelines, would deliver these epidemiologic studies from the plague of statistical significance. That is, in listing criteria for evaluating the quality of an epidemiologic study, guess what criterion EPA has carefully omitted? Statistical significance!

In its proposed cancer guidelines EPA specifically listed a number of criteria, but not statistical significance. Why? Was this an oversight? Hardly! With statistical significance out of the way, EPA's latitude in using epidemiologic studies to associate various substances and conditions with cancer has been significantly increased. Although included in the 1986 cancer risk assessment guidelines and, thus part of EPA's current epidemiologic criteria, the requirement of statistical significance has now been quietly deleted. Although EPA mentions that significance analyses should be conducted, achieving statistical significance is no longer an explicit requirement.

This actually comes as no surprise. For years, epidemiologists have been trying to do away with the hurdle of statistical significance. Thanks to EPA, it appears that they are well on their way to victory.

As proposed, the guidelines further enhance EPA's already virtually unfettered ability to label as cancer-causing whatever substance or condition it chooses. More important, however, given the public's acquired immunity to cancer fearmongering, the proposed cancer risk assessment guidelines pave the way for EPA to take a new stranglehold on society through the future assessment of potential health risks from environmental estrogens, the subject of Our Stolen Future.

Material presented on this home page constitutes opinion of the author.



Copyright © 1996 Steven J. Milloy. All rights reserved. Site developed and hosted by WestLake Solutions, Inc.

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