A Physician’s Perspective on the EPA’s “Data Derangement Syndrome”

Guest essay by Charles Battig M.D.

Derived from Heartland Climate Conference, June 11-12, 2015 Presentation by Charles G. Battig, MD: Panel 8 “Human Health and Welfare” June 11, 2015

In the latest iteration of propaganda tactics employed by eco-environmental activists and the EPA, emotion has become the chosen media tool. Mothers and children pose on the capitol steps and wave signs proclaiming their fight for clean air and the children’s health. Images of these “lovable lobbyists” for the EPA’s Clean Power Plan are heart tugging. It is maternal instinct vs. scientific debate; if it sounds bad, that is all that such moms need to hear, and in fact, it is hard to overcome such pleadings with cold facts alone. Such “do something” demonstrations find politicians and agencies all-to-ready to craft new legislation and regulations. I view this much like physicians who succumb to patients’ “do something” demands by prescribing antibiotics for the common cold…a useless, if not dangerous practice.

A general fear by the public for anything labeled a chemical or requiring some comfort with numbers is a powerful psychological tool for the alarmists. In-the-street TV interviews showing fearful reactions to the chemical name di-hydrogen oxide, which we recognize as ordinary water, is but one example. If the air is hazy it automatically assumed to be injurious to one’s health, but what about invisible toxins? The linear-no-threshold mind-set governs the government’s toxicology proclamations. One is to assume that any and all substances in any amount may be injurious to health, until proved otherwise. Forgone possible health or economic benefits of the demonized substances are not considered. Economist Julian Simon coined the term “false bad news” to describe the innocuous made to sound harmful by the media, when they target a concept and set-out to destroy it. Impartial and convincing scientific rebuttals are mostly ignored by the media since they specialize in publicizing bad news and perpetuating their own prejudiced agendas. Hollywood celebrities and politicians have become authoritative founts of scientific knowledge for the media-obsessed public.

The EPA reports that the six major EPA Clean Air Act pollutants are down some 62 per cent. Also according to the EPA, reported asthma incidence has gone up from 8.9 per cent in 2005 to 9.4 per cent in 2010. Why? Some possible factors are: increased public awareness; expanding its definition to include all reactive airway disease; and blunted development of natural immunity as the childhood environment is made perhaps too clean to challenge developing immune systems.

“Never let a hypothetical disease go to waste” and “look for those data that prove the assumption” seem to have been the bases for the “designer disease syndrome” the EPA has labeled PM2.5 (particulate matter 2.5 microns or smaller in diameter). PM2.5 is a most peculiar disease-causing agent when compared to traditional disease concepts such as Koch’s postulates. Its pathophysiologic mechanism is undefined, even by the EPA.

PM2.5 represents a mixed bag of substances united solely by being really tiny…they must pose a substantial health threat because the EPA says it believes it to be so. The particles have no unique chemical composition, and are known to arise from both natural and made-made activities. They vary in composition from one geographic location to another, and over periods of time.

The EPA claims that any inhalation of PM2.5 can cause death, including sudden death, as well as long-term deaths, labeled as “premature deaths.” Thus this substance is said to cause death from short term, long term, and in any dose exposure…really scary stuff. What level is the healthy level or safe level, and by whose and what criteria? EPA’s Lisa Jackson seemed to know as she testified before Congress in 2011 that: “If we could reduce particulate matter to healthy levels, it would have the same impact as finding a cure for cancer in our country.”

The EPA faces a science credibility dilemma. One the one hand it claims PM2.5 to cause death, but it is a postulated disease of statistical etiology. Epidemiological studies do not provide direct evidence of definitive causation, nor do they provide validated hypotheses for the biological mechanisms to do so. Thus the EPA needs to test humans, just to be sure. Volunteer applicants are supposed to be given informed consent. On the one hand PM2.5 is associated with death, but on the other hand it isn’t as they are told (page 21) that the “EPA has conducted 297 controlled human exposures to PM with only one clinically significant event, in which the study participant experienced no harm or injury.”

EPA testing has included both animal and human laboratory testing. Experimental designs must define what animal strains, what human test subjects, and what test dose size? Were all possible confounding factors identified and accounted for? Are these valid, random population samples, or biased selections? Computers can be programmed to find the sought-for correlations. Weak statistical correlations are presented as claims of proof of cause-and-effect. Data banks are trolled looking for that needle-in-the-haystack clinical correlation which can then be used to project concern to the general public.

The EPA has been conducting controlled human exposure studies to air pollutants on the University of North Carolina campus for more than thirty years. During that time more than six-thousand volunteers have been studied without a single serious adverse event being observed…so is there a health problem to investigate or not? How much more testing looking to define a disease? It looks more like a disease concept in search of a susceptible victim.

The Harvard Six Cities Study (Laden et al 2006) forms the scientific basis for much of the EPA claims regarding PM toxicology. Yet examination of the data shows that the statistical relative risk (RR) for total mortality claims range from below one to barely above one and a fraction. They do not meet the minimum legal standard of a RR of 2 to identify a significant population risk. In addition, these Harvard studies have walled-off their raw clinical data from independent investigators by claiming patient confidentiality, thereby preventing duplication of results by others. Independent reproducibility and verification of test results are the traditional hallmarks of scientific research. Invoking patient confidentiality to block access to raw data casts doubt on the entire process since providing such patient protection is not particularly difficult.

Representative Lamar Smith (R-TX-21) has led the effort to make governmental agencies provide open disclosure of the data and analyses used to formulate policy. H.R. 1030 is the Secret Science Reform Act of 2015, and was designed to ensure such ethical behavior. Public funds support most such research, and the public has the right to expect that its funds are used in an open and ethical manner.

The EPA claims that “epidemiological studies…have found consistent, precise positive associations between short-term exposure to PM2.5 and cardiovascular mortality…at short lags (0-1 days).” Zero to one day lag? Are near-instant deaths being predicted? So-called precise positive associations are not proof of cause-and-effect relationships.

In view of EPA PM2.5 mortality claims at 35µg/m3, why are airport smokers and the Shanghai population not dropping dead on the spot? Airport smoker lounges have ambient levels of 600µg to 10,000µg PM2.5. A single draw on a cigarette floods a smoker’s lungs with 10,000µg to 40,000µg. The Shanghai press reports PM outdoor levels of 600µg/m3. It also reports that the average life expectancy there is 82.5 years…a life expectancy greater than any major U.S. city. Where are the overflowing emergency rooms and mortuaries?

Carbon pollution has become the universal rallying cry of clean air advocates, including the EPA. On rational examination, the phrase is a scientific oxymoron. It is an open-ended, political propaganda term…a non-scientific sound bite pejorative of EPA origin. The EPA seems to have forgotten that humans are carbon-based life forms enmeshed in the Carbon and Krebs Cycles of life. Here is an orchestrated propaganda effort linking an essential component of life(carbon) in the Earth’s atmosphere with an emotionally laden, negative-connotation word…a sort of Saul Alinsky wordsmithing effort to create a new fearful sounding label with which to demonize fossil fuels…a psychological media campaign working to shape public opinion to fear the normal by invoking guilt-by-association. For example, the Federal government claims that “Greenhouse gas pollution threatens the American public’s health and welfare by contributing to long-lasting changes in our climate that can have a range of negative effects on human health and the environment.” Neglected is any quantification of “contributing,” nor validation of “range of negative effects.”

In June 2014, the EPA proposed the Clean Power Plan. Carbon dioxide (labeled carbon pollution) is to be “cut 30 per cent from the power sector by 2030, while maintaining an affordable, reliable energy system.” What about the negative public health impacts from more expensive, less available, and less reliable electric energy? Affordable by whom? What about loss of jobs and incomes to support good health and nutrition?

As we are all carbon-based life forms, such demonizing of carbon dioxide becomes an endeavor of self-denial and intellectual corruption in the service of justifying another encroachment upon our constitutional rights. The media and governmental agencies have labeled carbon dioxide as an unbounded scape-goat for any real or imagined societal or health ill. Yet, our lungs operate in an environment of 40,000 ppm even as environmental zealots fume over atmospheric carbon dioxide levels of 400ppm. Human-generated carbon dioxide is an essential plant food. In turn, plants produce oxygen essential for our life.

Global warming is decried as an environmental disaster in slow motion, yet winter vacations are preferentially spent by many in warm climes. Death rates climb in winter; asthma attacks climb in winter.

Atmospheric CO2 has not lived up to its panic-inducing billing. Over the past eighteen plus years, the average global atmospheric temperature as measured by satellites has remained unchanged. Over the same time period, atmospheric carbon dioxide has risen about 10 per cent. This failure has spawned a variety of new labeling terminologies such as climate change, climate disruption, and climate weirding; the only real disruption has been to expose the falsity of the CO2 scare story, and the attempt define manmade CO2 as the prime driver of global climate change.

In 2014 the EPA issued a reasonable sounding standard which stated that: “EPA’s task is to set standards that are ‘requisite’ neither more nor less stringent than necessary…The law does not require EPA to set primary standards at a zero-risk level.” What happened to the Precautionary Principle that so defines much of the EPA’s regulatory enthusiasim?

Don’t worry, it is here, on steroids…EPA-set standards are ratcheted ever lower by EPA director Gina McCarthy who is dedicated to her 2012 policy: “The best scientific evidence…is that there is no threshold level of fine particle pollution below which health risk reductions are not achieved by reduced exposure.” Zero dust outdoors even in the Great Smoky Mountains and in the pristine desert….a zero tolerance policy guaranteeing perpetual employment for regulatory agencies, and ever increasing electric power bills for all.

Continual ratcheting down of ambient ozone levels by the EPA is one example of the EPA’s ever-receding goal posts of what it defines as clean air. Once 75 ppb was enshrined into law, the EPA declared 60ppb to 70ppb as next goal. Neglected is the fact that ozone levels have been and continue to decrease in the US with measures already in place.

A 2014 EPA report titled “Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Ground-Level Ozone” claimed short-term exposure premature death savings ranging from sixty-five to three-hundred-and-fifty…out of a 350,000,000 population. These numbers are so small as to be statistical noise inseparable from daily random events. What is a premature death anyway? How does a physician diagnose a “premature death”? Premature compared to what other deaths that might have occurred that same day? Real doctors don’t see premature deaths; only computers sifting dodgy data, and using wobbly confidence brackets experience premature, statistical-deaths.

EPA-funded researchers reliably produce studies supporting EPA air quality objectives. Are such studies free of EPA influence and vice versa? The public reads headlines confirming EPA policy, even as the media ignore contradictory scientific studies. Borrowing from the fashion world, I term this “bespoke science” or made-to-order science. In 1961, President Eisenhower warned: “The prospect of domination of the nation’s scholars by Federal employment, project allocations, and the power of money is ever present – and is gravely to be regarded”…to which I say, how sadly true fifty years later.

Asthma has been adopted as the emotional picture-child for promoting EPA’s definitions of clean air by both the EPA and by President Obama. April this year, the president claimed that his daughter Malia’s childhood asthma was an example of the harmful effects of climate change. In the medical literature, asthma is recognized to be primarily a genetically based disease. Children 18 years of age and younger have experienced no changes in global temperatures or statistically valid measures of climate change during their entire lifespans. Yet, papers are published which cite correlations of childhood asthma with carbon dioxide as “due to” climate related factors. Observational data-combing is not statistically validated proof. Claims of linkage fail the test of validation and reproducibility. Asthma is triggered primarily by plant allergens, although susceptible individuals will react to a variety of physical allergens, including cold.

Steve Milloy’s Sacramento California hospital asthma admission study found no increased asthma admissions or deaths related to PM2.5; Stan Young and James Enstrom have already refuted these EPA claims with hard data, and more such studies are in progress. The EPA refuses to acknowledge these studies.

My anesthesia patients responded most keenly to my self-introduction as the doctor who was there to make sure they would wake up, not as the would-be guardian of the climate. Yet a Yale researcher would have anesthetic agent selection influenced by the recent finding of a few molecules of some popular agents in the Antarctic atmosphere. Exploitation of the public’s chemophobia and a loss of perspective by grant-funded researchers desperate to produce in a publish-or-perish academic environment add to the tidal wave of pseudo-science publications.

In conclusion, how might we counter this deluge of “false bad news”? As a physician, my guiding principle must be “First, do no harm.” Money and politics serve their own ends by preying upon the public’s health fears. This is a process abetted by a non-inquiring or biased media and activist groups. Those within the political process should recognize the pitfalls of catering to “just do something” provocations by enacting legislation based on fear and ideology, or financial gain rather than on sound science. Quite simply, the very real ills of unintended consequences follow from the wrong diagnosis of the wrong disease, and the wrong therapy.

Charles G. Battig, MS, MD, Piedmont Chapter president, VA-Scientists and Engineers for Energy and Environment (VA-SEEE). He is an “expert” advisor to the Heartland Institute. His website is www.climateis.com

43 thoughts on “A Physician’s Perspective on the EPA’s “Data Derangement Syndrome”

  1. ‘He is an “expert” advisor to the Heartland Institute.’
    Why the quotes around expert?

    • Heartland has a specific list of its “experts” available on its website…in this case it is their specified category/list of advisors…without the quotation marks it might be taken as a self-congratulatory adjective…
      CB

    • I think those are not scare quotes in this case, Jorge; the writer is telling us that the Heartland Institute lists him as an expert, instead of his just claiming that he is an expert.

      • I think in this case, it would be better to put the quotes around the whole term “expert advisor” to avoid that confusion.

  2. There was another interesting factor to consider as a contributor to the Increase in the incidence of reported asthma cases between 2005 and 2010…In March 2010 ObamaCare was signed into law and allowed for many undiagnosed cases to finally obtain a diagnosis. The increase could be a simple face of an increase in Per Capita access to medical care discovering existing but otherwise undiagnosed cases

    • If you simply DIE from your first major asthma attack and never saw the doctor beforehand for it it doesn’t count on the ledger. Surviving such an attack requires another person to be present with immediate access to 911 services with clear routing instructions for the drivers. (you simply will not be able to communicate over the phone on such an attack)
      I suggest to the discussion of this that the free Lifeline cellphone program combined with highly reliable GPS routing to sharply triangulated emergency locations could easily account for more than doubling the number of people surviving a condition in which attempting to move quickly or yelling for help results in fatal blackouts.. I looked at my wife and said “calm” then “ambulan” then “immedi” and stopped speaking to go sit outside in the cold.
      So, technically, Google is at fault for the increased number of Asthma cases in our society as their mapping, photography and topographical data collection scheme has reduced response time and increased accuracy of response of EMS arrival by more than all other improvement initiatives combined.
      Even with all this, the only thing that saved my life in 2007 was the record low temperature that January morning on which the associated air dryness and lack of healing of my lungs due to Acetaminophen cold medication caused an exceptionally rapid onset of the condition that I had never clearly experienced before. (Had attributed it to allergy since benadril always cleared the symptoms before.)
      Steam coming off my shaved head sitting in shadow outside at sunrise in a 28°F breeze wearing only a light pair of sweatpants keeping busy by forcing my lungs through spine flexing as my diaphragm started to fail. If I had panicked I’d have died. Panic is how most people with asthma die before they’re ever diagnosed.

  3. “They do not meet the minimum legal standard of a RR of 2 to identify a significant population risk”
    Link please.

  4. When a crisis is manufactured to suit a specific agenda logic is not necessary as long as you can repeat the crisis often enough and support it with manufactured ‘facts/data’. Today’s environment of soundbites and catchy-to-fit-in-a-smartphone-screen-headline is ripe for abuse. A manufactured crisis has a timeline that runs from “oh no” to “baloney” depending on its’ seriousness. Even “the earth is going to end on May 21, 2011” had followers due to the widespread publicity. CAGW will pass too as the claims either prove to be false as they have all along or they are pushed too far out for anyone to care. More people will realize that a ‘burn the village to save it’ strategy for a crisis they can neither feel nor see doesn’t make sense.

  5. In John Burnham’s book “How superstition won and science lost”, he postulated that superstition is functional for many people, thus explaining why it is difficult to eradicate, and identified advertising as the means by which superstitions with regard to health keep re-entering the popular culture. Environmental issues are simply an advertising opportunity for advocacy groups and bureaucratic agencies to promote themselves and solicit funds. No doubt some people in these groups have a sincere belief in their cause, but even they are taking us back to a time of magical thinking.

  6. It appears that one of the major concerns about the EPA’s claims is the lack of data supporting their position. Why do they need data? They can simply model it. The models will then generate all the data they need. This approach seems to work for them with everything else related to climate change alarmism.

    • The pattern of “threat” identification employed by the EPA is not in any way unusual and predates the existence of the EPA. The approach was developed by ambulance-chasing lawyers and is better known as the precautionary principle. By arguing that a specific condition, e.g. “high” concentrations of 2.5 micron airborn particulates, is “known” to be hazardous (which is true if the particulate is silica, or coal dust for instance, or some forms of other minerals) and then arguing that an agency of some type (governmental, business, etc.) should have taken precautions to protect people, they can take a pay check home when a jury incapable of critical thought hands down a civil decision.
      What the OP only brushes on is that there is growing evidence that there is a hormesis effect associated with many toxins and radiation (http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2477686/). The reality is that there is ample evidence that low doses of many toxins and radiation are actually protective. The OP mentions developmental “blunting” caused by excessively “clean” environments for the very young. Note that the link above is 1) a government page (NIH) and 2) is very critical of the US government response to very firm scientific evidence that our fear radiation for instance is overblown. The “government” is not monolithic in its response nor is it “antiscience.” What is antiscience is politicizing issues. The response of the antiimmunization gang Jerry’s (I guess he’s not all bad) signing of the immunization bill is a case in point. Annecdotal, cherry picked “evidence” has been employed for years now to “prove” that immunization is “bad.” There is no more scientific support for that idea than there is for assuming that humanity can trigger a catastrophic climate change (that is – none).

      • There is a Sad but very real solution to the Antiimmunization gang group belief. Simply let their kids enter school without their immunizations. Those parents with the foresight to have THEIR children immunized have nothing to fear. Then just let 1 case of undiagnosed measles or mumps enter the school population and watch it run rampant among the unprotected Antiimmunization crowd (they are the only ones that could then get the diseases anyway).
        Next phase, publically and innumerably inform the populace that Health Insurance will not be required to cover any expenses related to immunizable disease that available advance immunizations haven’t been sought to protect against. (Does not apply to newborns that haven’t been immunized yet or those that are documented as allergic to the immunizations).Perhaps once parents realize that it is only THEIR CHILD who will be getting sick and the Doctor Visits will cost them $200 – $400 out of pocket for each child each visit, their tune might change.

      • Duster – good response.
        There is something virulent in USA regulations which is called the ‘best available technology’ or BAT approach. It means the minimum standard for a product type is to be set at the performance of the BAT and whoever owns the patent on it sells licenses to anyone who wants to make that type of product. It sort of works for some things but is highly addictive – there is so much money in it for the winner that once an obviously good performance has been made normal, all meaningful risk removed, the ‘standard’ keeps tightening to keep a winner winning.
        The EPA is taking this approach but using it in the limiting of putative disease even if there is no provable risk left. The air got clean enough long ago. So they simply took the position that it is ‘never clean enough’ and they therefore should invoke the ‘best available’ target that can be met by ‘some means’. It has reached the stage of people abusing this approach to battle the coal powered generating facilities and many other popular targets.
        The EPA standards are informed by, or inform depending on this and that, by the WHO. Here is a model used to calculate the exposure to cooking stove emissions in kitchens in India. It is being touted as an ISO Standard (TC-285).
        http://www.who.int/indoorair/guidelines/hhfc/Review_3.pdf?ua=1
        There are 11 documents available in that set, this one contains the model. It was described by one expert I consulted as ‘sophomoric’, i.e. designed by someone who had learned a bit in first year and now they are in second year, thinks they can run the world.
        Notice something about the model: It assumes that smoke leakage into the kitchen from chimneys is 10% of the smoke emitted by the fire. Note that the fires are nowhere as clean as the EPA requires them to be. In short, the inputs to the model – smoke mass and leakage – are fiddled so that no stove burning solid fuel can pass the new, lower PM2.5 24 hr or 1 year target in the kitchen. No one would do that unless they were planning on regulating all solid fuels out of existence. Keep your eye on that ball. No matter how clean or sealed your stove, the model will fail it. Leakage and exposure will not actually be measured! That would lead to confusion.
        I thank for the EPA for doing a good job of cleaning up the environment but at the moment there are a couple of wheels off the rail.

      • Bryan, what the pro-vax advocates never question is that measles and mumps are unmitigated evils and that “herd immunity” is unquestionably desirable. I disagree on three counts. First, because fevers kill cancer; vaccinating against every childhood illness is short-term brilliant, but long-term stupid, in my opinion. Challenging the immune system is a good thing and perhaps a critical thing. Second, I fear the unintended consequences of mass vaccination if something goes wrong with the vaccine, such as happened with the Salk and Sabine polio vaccines in the ’50s and early ’60s, both of which were contaminated by a cancer-causing monkey virus. Third, with so much money at stake, the integrity of research into new vaccines may be undermined by the profit motive, as we have seen with “climate science.”
        In my opinion, vaccines are a two-edged sword and should be used judiciously. As with “climate science,” there is a tendency to assume we know enough, at any given point in time, to quantify risks and predict outcomes, but history shows that the scientific consensus is almost always wrong.

  7. Real Deaths by Indoor Air Pollution
    Contrast the real problem of poverty driven indoor air pollution. Air Pollution The Copenhagen Consensus

    “Air pollution is the world’s deadliest environmental problem. It kills 7 million people each year, or one in eight deaths globally. 4.3 million of these deaths are due to 2.8 billion people in the developing world who cook and keep warm inside their homes, by burning dung, firewood and coal – filling their living spaces with smoke and pollutants. Indoor air pollution from cooking and heating with open fires is equivalent to smoking two packets of cigarettes a day.”

    1% of global income could eradicate poverty.
    Far better to put the billions of dollars into clean cookstoves for developing world than waste them on power plants for immeasurable reductions in EPA’s “premature” deaths.
    Call you Representative or Senators and ask them to support: S.544 – Secret Science Reform Act of 2015 https://www.congress.gov/bill/114th-congress/senate-bill/544
    See Report: S. Rept. 114-69 – SECRET SCIENCE REFORM ACT OF 2015 https://www.congress.gov/114/crpt/srpt69/CRPT-114srpt69.pdf
    “OBJECTIVES OF THE LEGISLATION

    The purpose of S. 544, the ‘‘Secret Science Reform Act of 2015,’’ is to prohibit the Environmental Protection Agency Administrator from finalizing, proposing, or disseminating a covered action unless all scientific and technical information relied on to support the covered action is the best available science, specifically identified, and publicly available in a manner that is sufficient for independent analysis and substantial reproduction of research results.”

    Note:

    “EPA also has a record of relying on science conducted outside the Agency that is not available to the public—or to the EPA—and therefore cannot be replicated or verified by independent researchers.
    For example, virtually all Clean Air Act regulations under the Obama Administration have been justified by data sets collected by two non-governmental institutions over 30 years ago, which have been withheld from the public and cannot be replicated. In 2014, Congress learned this data either no longer exists, is of such poor quality that modeling results cannot be replicated, or has not been coded to facilitate independent analysis. However, EPA continues to rely on this data to support major regulations.”

    See related post at WUWT With Pollution Levels Dropping, is Small Particle Air Pollution Really Killing Americans?

    • Why just the EPA? Are other agencies (Dept of Energy, Dept of Education) pure in this respect?

    • David L
      I consulted an expert who has been following this ‘deaths’ thing for years. He says the real number from indoor air pollution is closer to 400,000 and even then, show us the bodies. There was a claim made in haste that 1600 people were drying in Toronto from the (almost zero) emissions of the Nanticoke power plant on Lake Erie (!) and that was the reply at the time: Show us the bodies.
      Indoor air pollution from cooking stoves is comes from a combination of the stove, the fuel, the operator behaviour and the burn cycle employed. But remember it is really a measurement of the kitchen, not the stove. Ambient exposure is governed largely by the kitchen architecture and air turnover rate, not the stove or the fuel. This is so basic as not to require mentioning. In the Third World where these fuels are commonly used there are a large number of people who cook essentially outdoors and their risk from outdoor air pollution is essentially zero.
      Just for the record, the figure of ‘deaths’ used to be Disability Adjusted Life Years (DALY’s) a woolly concept trusted by no one. It is highly dependent on models based on model-generated inputs. Garbage in, gospel out. Some time ago it was a million DALY’s, which magically/tragically became a million deaths, which means 2 millions DALY’s, really, which soon became 2 million deaths, which is really 4m DALY’s which turned into 4.3m deaths. Soon it will be 7m deaths – oh wait!

      • Crispin
        There is a strong link of poverty to lower life expectancy. e.g. see Our World In Data
        Just drive through Old Delhi at dusk when cook fires start up or most villages in the third world and you will see this effect. It is particularly strong where indoor fires are used to keep warm. e.g. see hills of Nepal, China, Mongolia etc. Just visit huts with smoke down to a few feet above a mud floor to begin to realize the impact.
        Ask you “expert” for references and documentation.

      • David L
        I am really familiar with the problem. I work professionally in this field. At the moment I am at an aerosol conference in Yantai, China. The links between smoke and claimed deaths are model based, and they are not necessarily good models (see link above and laugh), often/always concatenated. It is really easy to demonstrate that. There is very little hard data. Some would use stronger words. The number of individuals behind these ‘appalling statistics’ is surprisingly small and it is not very good work. Saying that of course opens one to criticism like, “Well, what have you got to show?” Cheap shots are not helpful, neither is cheap modelling. The number of claims deaths is very iffy. If you trace the root documentation it says things like “0-250,000 deaths” and within a few papers it says “250,000 deaths”. This has been done again and again.
        My expert replies: “Either WHO or Richard Horton recently made a call for better death statistics. So it’s not at all the case that these GBD people going door to door and hiring math/stat wizards have suddenly done anything final.
        “Besides, to my knowledge, GBD is about assigning death and disability to causes and then risk factors. The algorithms for this allocation cannot substitute for hard data.”
        Re smoky shanty towns, the dose/response claims are based on very little data and are mostly models going back 15 years or more. There is very little.
        1) How robust are the DALY computations on individual risk factors (not just HAP, because the burden of disease is the total burden of disease)?
        2) How much confidence can one put in the long-term results of attacking one risk factor at a time? This in turn is two sub-questions – Can it be done, and if it can be done, what results can be expected, against a dynamic baselines in specific vulnerable populations?
        3) What are the marginal gains considering that the overall burden of disease has changed? For instance, PM2.5 in low dosage probably doesn’t work the same mechanism on today’s and tomorrow’s obese and diabetic people as it did on the under-fed and physically more active populations born in the 1920s to 1940s.

  8. Patient confidentiality is a non-issue and all universities know and manage this with their Institutional Review Boards which establish and supervise confidentiality of all human subjects testing. No study is legally allowed to go beyond proposal if it cannot guarantee subject confidentiality with public release of data. These standards in the US were created by the National Institutes of Health and are required to be in place and administered by all organizations, including Harvard, that engage in human subjects research.
    If an investigator or an organization claims it cannot maintain subject confidentiality, it either cannot conduct the study (possibly may not have and it is a fiction) or, if it does, it is in violation of federal law.

  9. So goes the story also on nuclear science. One of the reasons that “waste” is perceived as an insurmountable problem is the brainwashing of the public that ANY exposure is damaging. Goofy regulation required beyond all reasonable engineering thresholds! To the point that we are stuck with a policy does doesn’t deal with “waste” at all. The Union of Concerned Scientists is the original IPCC.

    • I think you have a very good point. A lot of the current EPA/progressive scary narratives use analytical methods and protection techniques that originated in the nuclear industry, to deal with the stochastic nature of radiation hazards. The LNT concept originated with the fact that there is only somewhat good data for high exposures (mostly fatal high dose rate doses), and the risk at doses near natural background is so small that it is impossible to even identify (talk about teasing a “signal” out of noise!). However, there is a well defined mechanism which supports the argument that one “hit” is all it takes to cause a cancer. This is without considering repair mechanisms and many other factors. So, using LNT for radiation was considered “prudent” (sound familiar?). And there is another principle called “As Low as Reasonably Achieveable” (ALARA) which was developed to encourage organizations that use radioactive materials to do everything reasonably possible to get doses down, because of LNT.
      These two principles were perverted by anti-nukes into “no known safe level of radiation” and all sorts of ultra-conservative limits for exposure pathways for waste in repositories, thousands of years into the future.

  10. In 2004 a doctor told me I had 5 years left to live (from the diagnosis of a test performed in September 2003). Now, regardless of whatever is going to happen it’s undeniable that it is now utterly impossible for me to experience a premature death.
    Premature orgasm, yes. Premature death, no.
    Now, my question is: Does the EPA have a metric, not for premature death, no, for post mature death? And unless the undeniably carbon based life forms at the EPA have a metric for post mature death (which a modern, affluent, industrial society surely provides) then, as far as I’m concerned, their allegations (and that’s all they are) about premature death are unfalsifiable crap. And, if a doctor (thus far and counting) is over 220% off in a life expectancy prognosis for a single patient, well, I’d be damned if I’d give one iota of credence to those smarmy control freaks at the EPA giving the same prognosis for 300,000,000+ people.

    • what makes you think they are “undeniably carbon based life forms at the EPA”? :>)
      So, things are good in Vermont, thanks for asking the other day and glad you’re still with us.

    • Naw, The doctors in 2004 were obviously looking at the wrong Hockey Stick to divine your early departure date. Contrary to popular belief, your “best if used by date” has been extended to a point that will coincide with your actual departure date such that you will expire 3 days prior to your new undefined expiry date. Thus still giving you a Premature Death associated with PM 2.5

    • Even someone who dies in their 80s or 90s that smokes at the time of death is considered a smoking related death. Helps the AMA boost the stats.

  11. The 62% claim doesn’t match the link provided. It says 62% reduction in NOx from 2003-2008, and 72% reduction in six pollutants from 1970-2012.

  12. Why is the EPA, not the CDC, responsible for identifying PM2.5 disease? Shouldn’t the CDC be the one saying there is a problem? Only then should the EPA becomes involved.
    Otherwise, if a single department becomes both judge and jury, where are the democratic controls necessary to preserve freedom?

  13. April this year, the president claimed that his daughter Malia’s childhood asthma was an example of the harmful effects of climate change.
    ===================
    more likely the harmful effects of not exposing children to dirt. healthy children eat dirt. they become host to millions of organisms that live in dirt. organisms that our ancestors co-evolved with over hundreds of millions of years. without which we develop disease.
    90% of the cells in our body do not share our DNA. yet we fail to understand how important the 90% is to the health of the remaining 10%.

  14. After working with the impacts of EPA’s regulations for the past 7 years, I have come to realize they use data to further their political agenda. Their data does not have to be real, accurate or reproducible, it is just a blank they fill in to obtain results that are established before the data collection or study is even begun. Only a few people have the expertise and motivation to even read EPA’s data and discover the problems.
    This is not just my stupid opinion. Example: EPA’s proposed new wastewater regulations for power plants has very low limits for selenium set by the study of data from just two power plants in North Carolina, using technology that is close to being experimental. The limits established will apply to every coal power plant in the country. The company that runs the two plants has told the EPA that even those two stations cannot actually meet the new limits under real world conditions of varying fuel supply and operations. This is because in EPA’s data assessment, they threw out higher data points, calling them “upset” conditions and not indicative of actual operations, even though they are real responses to changes. EPA wanted to establish the tightest limits possible and tortured the data until it gave them what they wanted. This is just one example out of many.

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