(Originally Posted: 11.02.1997)
420 Cannon House Office Building
Washington, D.C. 20515-3006
Dear Mr. Pallone:
From time to time, you have been portrayed in the local press as being dedicated to environmental issues. Therefore, I am taking the time to write you about the clean air standards being promoted by the Environmental Protection Agency.
What I am about to say, you may find not to your liking, but it must be said in the name of rationality and common sense. From what I have seen on the Internet and in respectable scientific journals, these standards are themselves based on junk science.
The core of this junk science indulged in by the EPA is the so called epidemiological study. This study is nothing more than a medical equivalent of an opinion poll.
When Carol Browner announced that the EPA standards were based on 250 studies, she dissembled the fact that these studies were merely epidemiological in nature. The epidemiological study has its place, but sadly it has been abused to a fare-thee-well by Ms. Browner and her department.
The abusers in the EPA are akin to wannabe lawyers who eschew the hard work required by law schools and instead pontificate on legal matters because they’ve gained some familiarity with the vocabulary. The epidemiological abuser passes out questionnaires, and by playing statistical games with the responses purports to have discovered the causes of illness without doing the hard work required by laboratory experiments.
The weakness of these studies touted by the EPA, in connection with their clean air standards, is their failure to explain the difference between causality and correlationship. Causal relationship: A causes B; correlation: A & B are found together.
Should Frank Pallone be seen exiting from a hotel with a young, beautiful woman not his wife, only a correlation not a causal relationship may logically be concluded.
The epidemiological studies, relied on by the EPA, are solely observational. As such they cannot and will never by themselves, prove a cause and effect relationship which may or may not exist. The best that can be expected from these studies is a correlation of degree – are two things found together always, sometimes, never?
For years, people had noted a correlation between systemic infections and the eating of uncooked meat. It took laboratory researchers to discover that intestinal illness was caused not by the uncooked meat, but by bacteria, and a certain kind of bacteria, E-Coli. The trouble with epidemiological studies is that there are just too many incidences of variables, known in the trade as biases and confounding factors.
A measure of air-pollution in two cities compared with the number of recorded deaths from respiratory illness is but a measure of only two of many variables. Neither the cities, nor the residents, are wholly identical, except for the level of air pollution.
Unfortunately, junk science is exaggerated by junk journalism and junk politics. Pseudo-environmentalists lay claim to certain factors in the environment increasing the risk of some disease by a certain percentage. What is left unstated, I have noticed, is the risk, because it is often negligible.
If the percentage of your risk in catching HI (Horrible Illness) by leading a normal life is .00000013 and eating Kiwis increases that risk to .00000039, do you care? Should any rational being care? And yet, the bureaucrats at the EPA frequently use such math to justify a press release to the effect: “Eating Kiwis increase the risk of contracting HI (Horrible Illness) by 200%. WOW!!!
When considering risk, please bear in mind that we are all mortal, that life is fatal, and every moment we live is filled with risks. We measure risks in relative terms, by measuring them against the benefits of taking them. (I may be hit by a car while mailing this letter to you, Mr. Pallone. Nonetheless. I assume that risk because I think what I have to say to you is important.)
The weighing of risks has always been a function of human activity. That is until the EPA, pseudo-environmentalists, sundry junk scientists, pop-journalists and untutored politicians insinuated themselves into the debate and began to assert that there is no such thing as a cost-benefit ratio. In their case, sir, I would say the cost is too high, and the benefit is zero.
Marc C. Kollar