Opinion by Kip Hansen — 24 January 2020

In Part 1 of this two-part series, I detailed how there has been a growing furor over the U.S. Environmental Protection Agency’s (E.P.A.’s) proposed “Strengthening Transparency in Regulatory Science” rule — most often referred to as the Secret Science rule. A majority of the expressed concern about the rule deals with the Harvard Six Cities Study — which is being defended by opposing the proposed E.P.A. rule. Here’s why:

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This is a perfectly fine preliminary study of the topic. It has a major finding of :
“The adjusted mortality-rate ratio for the most polluted of the cities as compared with the least polluted was 1.26 (95 percent confidence interval, 1.08 to 1.47). Air pollution was positively associated with death from lung cancer and cardiopulmonary disease but not with death from other causes considered together. Mortality was most strongly associated with air pollution with fine particulates, including sulfates.”
Conclusion:
“Although the effects of other, unmeasured risk factors cannot be excluded with certainty, these results suggest that fine-particulate air pollution, or a more complex pollution mixture associated with fine particulate matter, contributes to excess mortality in certain U.S. cities.”
The study had, in total, 8,111 subjects , all white — in six different cities — roughly 1300 subjects per city. Of these, there were 1429 deaths over the 14-16 years follow-up or about 230 deaths per city. The city-specific rate ratios are all expressed in relation to Portage, Wisconsin.
The results? Summarized in the original study as:

Only the highlighted categories have Confidence Intervals (CIs) that DO NOT include the NULL (risk ratio of 1 — which indicates no difference in effect found). All of the CIs that don’t include “1” have a range that starts very low. The chart shows clearly that it is chiefly Former and Current Smokers and those with Occupational Exposure (to gases, fumes, or dust) that show even a simple associational effect from fine-particulate air pollution.
Another look at the data from the study:

Again, we see (highlighted in PINK) that it is Current Smokers, Former Smokers (but not evenly — only female former smokers and 10-Pack-years male former smokers), men with less than a high school education [probably a marker for socio-economic status – kh] and women with high BMIs that show even small associational effects. ALL other classifications show the 95% CIs include the NULL effect rate ratio of 1.
The cities are listed in order of least-pollution to highest-pollution. ONLY Steubenville — highlighted in YELLOW — the most polluted city, has a significant result, and that only for men.
What does “includes the NULL effect rate ratio of 1” mean?


These two cartoon images demonstrate that Rate Ratios that include the rate ratio of 1 are compatible with the NULL hypothesis that there is NO EFFECT. For a result to be significant and reject the NULL of No Effect, the Rate Ratio must NOT span the rate ratio value of 1.
What does that mean for the Six Cities study findings?
Very few of the statistical results in the Six Cities Study meet the requirements for being significant and rejecting the null hypothesis of “no effect”. Those that pass this simple basic test have results that are very small and are directly related to other known causes for the posited effect — smoking, occupational exposure, low socio-economic status, and high BMI. When comparing “more polluted cities” to the “least polluted city” ONLY ONE city, the most polluted city — Steubenville, Ohio — shows any significant effect at all. Even with Steubenville, the effect is very small with a rate ratio of only 1.26.
For a short introduction on the topic of evaluating environmental epidemiological results, see this seminal paper: ”The environment and disease: association or causation?” by Sir Austin Bradford Hill from the Journal of the Royal Society of Medicine.
Let’s look at Sir Austin Bradford Hill’s six factors for considering results:
- Strength of the association — The Six Cities effect findings are very small — effect ratios are not 4 times, 10 times, 40 times — the strongest of the findings between cities is only 1.26 with a CI of 1.06 to 1.50, barely missing including the null (no effect) value of 1.
- Consistency of the observed association: The Six Cities findings are not consistent across cities’ air pollution levels, or between genders. The greatest consistency is with smoking status — current or former — but not with air pollution levels.
- Temporal relationship of the association – which is the cart and which the horse? The Six Cities study followed the cohort for 14-to-16 years. There is no data in the published study that relates how long the subjects lived in the cities under consideration — so this factor cannot be evaluated.
- Biological gradient, or dose-response curve: The rate ratios between cities — by pollution levels — do not demonstrate a dose-response curve — effects are not consistently larger as pollution levels increase, effects are not consistent between genders, and only the most polluted city shows a significant effect, and that only for men.
- Biologically plausible? It is biologically plausible that air pollution could cause increased mortality. It is not biologically plausible that air pollution would only cause increased mortality in the pattern shown in the study results.
- Coherence — association “should not seriously conflict with the generally known facts”: The results are coherent with some known factors: Smoking (current or former) causes increased mortality, occupational exposure to “gases, fumes, or dust” causes increased mortality, low socio-economic status is associated with increased mortality, and high BMI is associated with increased mortality. Extremely high levels of air pollution, think the killing smogs of London in the 1950s are associated with increased mortality. So, it is possible that air pollution at the levels found in these six cities could cause increased mortality. However, the weak results of the study are not sufficient to show this to be the case.
This quick review of the Six Cities study is not meant to be a serious or deep-dive analysis — it is just what is seems, a quick overview of its strengths and weaknesses. Despite claims from the Harvard’s T.H. Chan School of Public Health that this study revealed “a strong link between air pollution and mortality risk”, this review highlights why there is concern — bordering on the hysterical — that the authors might be forced to make the underlying data available for re-analysis by researchers not involved in the original work.
And the other studies being protected by anti-STIRS efforts?
Here’s the famous California study:
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These are Relative Risks — only those highlighted in yellow are significant. All others have CIs that include the null effect value of 1. The most biologically plausible effect for PM2.5, lung cancer, has the highest RR for PM2.5 of 1.103 (0.985-1.234), highlighted in pink — vanishing small and failing the significance test.
The concern seems to be that if these results were to be re-analyzed by others, outside the original research group: Would even these very small associations disappear? Or would the re-analysis team deem them so small as to be irrelevant to anyone’s health?
Are such tiny effects real in the Real World?
I am not a statistician nor am I an environmental epidemiologist. I do have a good head for numbers — and I understand the basic concepts discussed above.
I can see why there is concern among researchers who have been advocating that very small amounts of air pollution are dangerous to the health of Americans (and, by extension, all humans) that these studies might be re-examined in the light of rigorous and strict scientific and statistical standards and found wanting. If they were my studies — and thus my reputation — I would be running scared at the idea that someone would really dig in, armed with all the original data, from a duly skeptical viewpoint and expose the inherent weaknesses of the analysis and subsequent findings.
When effects are this small, it is extremely possible that the effects are not real, but are artifacts of the statistical methods used in the original analysis. If these findings had had Relative Risks or Risk Ratios of 4.0 or 7.9 or any value that might indicate a strong association, then I would be more convinced. But with so many of the metrics not even passing the most basic test of significance, I am concerned that the findings represent only what John P.A. Ioannidis has termed “simply accurate measures of the prevailing bias.”
We see, in the defense of these studies, the wrong-headed viewpoint often found in some scientific fields, including epidemiological studies, that “lots of studies finding small associational or correlational results” are equal in truth-value to “one or two studies that find incontrovertibly strong results.”
High-time for Re-analysis
The problem with foundational studies such as these is that later work is based on the supposition that these studies findings are discovered truth and thus these studies’ findings are used as starting points, assumptions, in future studies. With so many governmental regulations being based on studies such as these, maybe it is high time that the basic data from these studies — suitably cleaned of data that might identify individuals and reveal their personal health information — be made available for strenuous re-analysis by disinterested researchers and statisticians. This is the stated purpose of the E.P.A.’s proposed “Strengthening Transparency in Regulatory Science” rule.
If the evidence from the studies is strong and convincing, and their methods valid and proper, then the studies will be upheld and their results validated. If not, then Science might possibly begin the process of scientific self-correction.
In either case, there is no downside, it is a Win-Win: the state of human knowledge will be improved and advanced.
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Author’s Comment:
This is an OPINION piece. Please feel free to disagree with my opinion and leave comments expressing your opinion.
This Secret Science battle is very important — if the forces of common sense and rigorous science prevail, the world will be better for it. If not, we will be condemned to be ruled by weak correlational research findings that are fueled by the desire to provide support for advocacy positions — many of which are not, in the commonly accepted sense, a reflection of the real world.
Beginning your comment with “Kip…” will ensure I see it if you are speaking to me.
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It might be that, apart from sound science, the EPA is setting up to more rigorously regulate based on abatement costs. There is a huge difference between a regulation that costs $25 per (statistical) life saved, and one that costs $500,000,000 per (statistical) life saved. The weepy left has no problem ignoring economic reality and the fact that idea that there are only so many resources available. Look at Bernie’s fanbase.
There are obviously benefits to whatever is producing particulates; otherwise they wouldn’t be being produced. And based on the statistics in this article, there may be a slight cost. Most of us drive or at least ride in automobiles. There is a statistically significant risk to doing so, yet most of us make the assessment that the benefits of car travel make it worth it.
When telling other people what to do and what to spend, the lefties just want you to take their word for it that it’s worth it.
Kip
Things may start changing. Here is a link to a recent large study about the effect of air pollutants in California. They found no effect as given in the Abstract.
https://doi.org/10.1016/j.yrtph.2018.05.012
While the article is pay walled, you can find the following under the provided Highlights:
“The data set and analysis code is available”
rd50 ==> Yes, Stanley Young has been doing some great work – there is hope.
It is amazing to me how our God-given Constitutionally guaranteed rights are so easily ignored and violated when some quack of a “scientist” (or bureaucrat) says they must be “for the greater good”.
It is one thing to have laws that proscribe direct and obvious pollution by one entity upon another. It is entirely different when all of society must suffer penalties for amorous “associations” or “correlations” of speculative and indeterminate causes.
Our rights should not be so casually discarded. When environmentalism becomes authoritarianism formerly free people become slaves.
With 6 cities, and stats broken down for men and women, that’s 12 data points, The probability that at least one of them will hit the 5% significance limit by chance alone is 1- (0,95)^12 =46% , underwhelming,
Alan ==> Whenever overall data is broken down into smaller and smaller bits to compare with one another or the null, it increases one’s chance of “finding” a “significant” result.
Significant doesn’t mean real or important.
Another issue not mentioned is the loss to follow-up rates. Does the paper have those? In many studies this is not given, or it is not stated that the analysis was on an ‘intent to treat’ basis. This is imporant.
FranBC ==> There was a follow-up to the Six Cities Study see: https://wattsupwiththat.com/2020/01/23/secret-science-under-attack-part-2/#comment-2900521
ALL research, other than classified, funded by public money should be required to publish all data, methodologies, and associated code.
In addition, any data being used to inform public policy, regardless of original funding, should be subject to the same standards. Any arguments to the contrary are just CYA.
I believe the driver here is the need to have a positive results in any funded research. No government agency, be it public health or climate policy, wants a research project to come back with “no problems”. The same bias flows down to the researchers as well. Knowing taht if they produce NULL results, that will be the end of funding.
CBS JR ==> I posit that the driver is the desire to support certain advocacy positions — for fame or funding.
“between genders”
Sexes, not genders.
in the context of the sentence either works. You are once again being unnecessarily nitpicky. Nobody like grammar nazi’s
John ==> I don’t mind — people have differing opinions on that topic — and definitions have changed and are changing.
It’s about using the proper words. Sex is biology. Gender is behavior, regardless of how the “woke” people want you to believe that they are the same thing. How is that being nitpicky?
It’s being nitpicky because in the real world use of language either word can be and are used in the situation under question. sorry that’s too hard of a concept for you to grasp, Words aren’t as restrictive as you want them to be. Stick to dead languages is you want unchanging word usage.
Biology and attributes, respectively. Unfortunately, there are diverse sociopolitical motives to conflate characterizations.
Male and female, certainly. Although, there may be a correlation with masculine and feminine physical and mental attributes, too.
There could also be a sociobiological orientation a la “women and children, first”. We live in interesting times.
Kip…
“provide support [for] advocacy positions”
🙂
Jeff ==> Thank you, good catch.
Kip
Thanks for the excellent article.
I am currently reading Robert Sapolsky’s Behave.
He is continually describing all the seminal behavioral studies that decades later were shown to be wanting.
He also puts caveats on just about every study.
So my interest was sparked by this study. It seems a parallel to many of Roberts examples
Waza == You are welcome, — I’ll have to check out Sapolsky.
Nikhil Desai says it all in one short sentence:
“Disease incidence in specific cohorts and burden of disease among the premature dead are entirely unrelated.”
Kip
Is electrosmog harming our heath ???
The evidence showing harm is overwhelming
In 2007, the Bioinitiative Working Group, an international collaboration of prestigious scientists and public health policy experts from the United States, Sweden, Denmark, Austria, and China, released a 650-page report citing more than 2,000 studies (many very recent) that detail the toxic effects of EMFs from all sources. Chronic exposure to even low-level radiation (like that from cell phones), the scientists concluded, can cause a variety of cancers, impair immunity, and contribute to Alzheimer’s disease and dementia, heart disease, and many other ailments. “We now have a critical mass of evidence, and it gets stronger every day,” says David Carpenter, MD, director of the Institute for Health and the Environment at the University at Albany and coauthor of the public-health chapters of the Bioinitiative report.
Wi-Fi is an important threat to human health
“Repeated Wi-Fi studies show that Wi-Fi causes oxidative stress, sperm/testicular damage, neuropsychiatric effects including EEG changes, apoptosis, cellular DNA damage, endocrine changes, and calcium overload. Each of these effects are also caused by exposures to other microwave frequency EMFs,”
https://www.sciencedirect.com/science/article/pii/S0013935118300355
jmorpuss ==> Perhaps I will spend time to write a piece on that study — it is seriously flawed in conception and assumption.
I will look forward to that piece Kip.
I would be interested in seeing something on that subject, too.
Ah, statistics.
Problems abound in collecting statistics concerning human health.
So few really understand what errors can take place in statistical studies.
First is selection error: to be representative, a sample must be random. Herein is the problem with polling. How does one account for the non-respondent? If a sample is random, the individual has no choice about being included. If the person has a choice, the sample is no longer random, since the non-participants are not represented.
Second is false precision: all measurement has margins of error, no matter what is being measured. If these margins of error are neglected, then a false narrative is produced. Herein is the problem with like/don’t like polls. If individuals have different standards for liking or not liking, then the result will be skewed.
Third is the tendency of samplers to change the rules during the collection of data. If a rigorous scheme is not set up at the outset and followed through to the end, errors of bias of one form or another must creep in to the data.
So what does it mean to be statistically significant? Must we follow Pierson, who chose the 95% standard over a hundred years ago? Or are there other choices for significance?
Kip: thanks for these articles. This is important. All this crap about PM2.5 is a masquerade for banning diesel motors and then all ICE vehicles, ie the crusade against fossil fuels.
Yep! Funny that EPA experiments pumping pure diesel fumes straight into human subjects didn’t kill any of them. The old lady with the dicky heart had a scare but that was it.
Greg ==> I am afraid you might be right.
why do my comments go to moderation all of the time ! :-((
This has been going on for quite sometime.
Streetcred ==> They may not be going to moderation….there is a lot of technical stuff going on behind the scenes — caching, auto-moderation, hand moderation — sometime my comments are delayed and I am the AUTHOR!
The comment section is not a live chat function…..
Kip, thanks … except that they appear for me with a note that they’re in moderation. 😉
Street ==> It can happen — to anyone.
“except that they appear for me with a note that they’re in moderation”
I get that sometimes. It usually happens when a flagged word is included in the post.
Most other times when I post, the post will disappear for a period of time with no notification provided, and will appear later(within about an hour). I’ve only had one post disappear completely and never come back. And then very rarely one of my posts will appear as soon as I post it. Maybe one out of 100.
The comment software is going to be updated in the near future, so maybe things will get better. The last time it was updated, some glitch occurred, and screwed everything up to the point that Anthony was having a hard time even getting logged on to his own website! Let’s hope that doesn’t happen again. You never know what’s going to happen with new software sometimes.
On “In Moderation” ==> The whole subject of moderation is tricky and controversial. The point of moderation is to keep abject trolls who are disruptive and offensive intentionally — not as part of what we hope to see which is constructive conversation — which can and should include disagreement,
even strong disagreement.
It would be nice to have paid professional moderators sitting by every minute of the day to do this important work — but the fact is that everyone here is a volunteer — some putting in more time than others — and that’s not possible.
So the system has some built in automaticity — checking for certain words and phrases like death threats, foul language, too many links, etc etc — I’m not sure what all the programmatic rules are.
What readers seem to want is a Live Chat-like system — but that just can’t be — it would be overwhelmed by trolls in seconds.
There are plans a foot to improve the commenting system, including mandatory registration — which will smooth things out.
So, in word, PATIENCE PLEASE. (well, two words.)
Hi Kip, love your work.
On a similar note I have an interesting personal story. My mother was a serious chain-smoker when I was a child (early 60’s). I joined the Navy at 15 and my experiences included exposure to asbestos, beryllium, cadmium, PCB, RF radiation and as an aside a war zone. Very recently diagnosed with lesions in two arteries in my heart and a radical prostatectomy thrown in. Interestingly the Veterans Affairs department has a ‘Non-liability Health Care’ clause that provides free health care for ANY cancer. I imagine that this resolves either party from proving (or not) cause. My point for this note is that the science behind the recent glyphosate BS is even thinner than the ‘6 Cities’ study. How is it that courts can decide on the validity of a scientific study?
Have a great day.
Oh, P.S. I have never attempted any claim I have put my circumstances down to ‘life’.
Andy
Andy ==> Thanks for sharing your personal story. Liability is a tricky issue — and best left to obvious cases of intentional neglect leading to harm (or something like that).
7th amendment to the US constitution guarantees trial by jury in matters of $20 or more. The typical american on a jury has no scientific background. If its the big bad corporation vs the little guy you know who is going to win. I remember the comments by the jury foreman in the first VIOXX trial of years ago. A reporter asked what he thought of all that science. The foreman answered oh we didn’t understand any of that science…
Kip: In one sense, I’m already ahead of you!
https://wattsupwiththat.com/2017/08/11/the-social-costs-of-air-pollution-from-cars-in-the-uk/
(It’s a long article – and huge thanks to Charles for accepting it while Anthony was indisposed).
I didn’t mention the Six Cities study in that article, but the American Cancer Society study from two years later came out with similar results. And if those results turn out to have been wrong, that will take away most, if not all, objective “rationale” for controlling people’s lives for reasons of air pollution. I leave it to the readership here to assess the magnitude of the social and political consequences, if that proves to be the case.
Oh, and in 2000 the “Health Effects Institute” was allowed access to the Six Cities data to validate it; and gave it a (no pun intended) clean bill of health. Might there be a “Climategate” in this area, too? I’ve lost the link to the one page summary, but here’s the full report:
healtheffects.org/system/files/HEI-Reanalysis-2000.pdf
Neil ==> Thanks for the link to the HEI reanalysis. “HEI is a nonprofit corporation chartered in 1980 as an independent research organization to provide high-quality, impartial, and relevant science on the health effects of air pollution.”
They are primarily funded by EPA — their goal to to assert harms from air pollution.
If we based policy on the raw data in the California study, one could reasonably conclude that high ozone levels are helpful in preventing lung cancer, since the mortality ratio (confidence interval 0.719 to 0.964, median = 0.832) is less than 1 outside the 95% confidence interval.
Of course, no one would reasonably say that industries should emit more ozone, because low-altitude ozone forms from reactions between nitrous oxides and volatile organic compounds in the presence of sunlight (and oxygen normally present in the atmosphere), and those other pollutants do have deleterious effects.
But this example does demonstrate the absurd policy that could result when cherry-picked results from relatively inconclusive studies are used to justify environmental rules.
Any reasonable study that would be used to check the health effects of air pollution should exclude all smokers (since smokers voluntarily poison themselves with high doses of pollutants regardless of the surrounding air), have all subjects grouped by age and sex for comparison between those exposed to more or less pollution, and have measures of susceptibility to disease plotted against a dose of pollutant in units of (mass/volume * time), such as ppm-years or ug/m3-years.
EPA should provide scientific transparency by forcing those who perform these studies to publish their raw data (not only the conclusions), so that other scientists can check whether the conclusions are valid.
Since this website is devoted mostly to global warming by CO2, the requirement to actually check raw data is even more important when dealing with supposed catastrophes which would result from extra CO2 in the air. Computer models have notoriously over-predicted the temperature rise and sea-level rise due to increasing CO2 in the past 40 years. The re-analysis of Michael Mann’s raw data has debunked his hockey-stick graph.
How do we know how much temperatures will rise in the future if CO2 emissions continue to rise, since the models have been wrong in the past? If temperatures warm by more than 1.5 C in 100 or 200 years, how can we quantify how many people would suffer, relative to how many people would benefit from warmer temperatures? The only way to estimate this would be to study life expectancies or death rates during exceptionally cold or hot years in the past. We would need to study how the frequency of violent storms, floods, and droughts vary with temperature in various areas of the world over a long period of time. Due to the variability of weather not only with CO2 concentration but by location and season, it is likely that such studies would be rather inconclusive, and not necessarily predict a catastrophe if the global average temperature rose by 1.5 to 2.0 C.
Such results would not help the scaremongers’ cause of trying to force people to spend trillions of dollars and endure much discomfort for a fossil-fuel-free future to prevent a non-event, but that would be true science, and would show that scientific expertise is better used trying to improve the living conditions of everyone in the world, whatever weather nature has in store for us.
Hi Kip,
Here is another typo for those of us who are obsessive-compulsive proofreaders.
Effect rations–>effect ratios
“Strength of the association — The Six Cities effect findings are very small — effect rations are not 4 times, 10 times, 40 times . ..”
Nice paper, as usual
Robert ==> I caught one of those auto-spell correction errors with the same word — ratios — somewhere else.
Thanks for your good eye!
Hi Kip,
Here is another typo from a obsessive-compulsive proofreader
effect rations –> effect ratios
“Strength of the association — The Six Cities effect findings are very small — effect rations are not 4 times, 10 times, 40 times . . .”
Another nice paper–as usual– from your consistent and impressively productive output
PS. Sorry if this is a repost. I’m using an unfamiliar iPad and was not sure I filled out the required field
Robert ==> Thanks — I do appreciate these corrections — even if duplicated. Proofreading is VERY difficult for authors who tend to see on the page what they intended to write.
My wife, however, was, in her earlier years, a professional proofreader for magazines — and is terrific — but I seldom ask her to do technical articles.
Wow, thanks — you have courage, Kip. Criticizing the six-city-study is criticizing their Bible — blasphemy! This is their whole justification for trying to control every dust-mote created by any human activity.
beng135 ==> I looked into the Six Cities study because all the the EPA Secret Science rule detractors mentioned it as their primary concern. I was shocked at how weak and inconsistent its findings are.
Thank you Kip, for your studies and also being so conscientious replying to remarks.
Epilogue:
Thank you to all the readers here for there terrific response and intersting discussion of the issues involved in the EPA Secret Science rule battle.
As a final note here in the questions raised in my criticism of the Six Cities study, readers should understand that I have not said, nor am I saying, that severe air pollution, indoors or outdoors — either from combustion sources like factories and internal combustion engines or from smokey heating and cooking fires in the homes and huts of the poor in the Third World — is not harmful. I have visited and shared meals with families living in such conditions, and I am fully aware of the harms that can come from breathing heavily polluted (smokey) air hours on end every day. I grew up on Los Angeles, California, in the 1950s — when smog made the air acrid and stung one’s eyes — where nearly every individual household still burnt their trash in backyard incinerators just like my family did — where recess in schools was cancelled on the wqorst days and kids kept indoors to protect them. Such conditions have been corrected through strong efforts to reduce air pollution.
But the Six Cities study simply does not present evidence of harm caused by very small quantities of PM2.5 — not by any standard required of strict scientific investigation — nor does the HEI re-analysis or any of the subsequent follow-up studies.
With the E.P.A.’s “Strengthening Transparency in Regulatory Science” there is hope that some of this science can be reviewed in a new light by professionals not involved in the original research and without vested interests in the outcome.
Above all,
Thanks for Reading!
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