ASA Urges EPA Proposed Rule Be Withdrawn or Rejected

“Important, useful, and valid studies that have not, or cannot, make available the data on which they are based still have scientific value,” according to a recent public statement made by the American Statistical Association. In the statement, the ASA also urges the rejection of a proposed new rule mandating the Environmental Protection Agency (EPA) use only scientific studies that make their underlying data available when deciding on significant regulations.

While recognizing and appreciating the efforts to increase transparency and make more government data available while protecting confidentiality, the ASA notes that the consequences of the rule will impoverish evidence-based policymaking.

Many kinds of research studies—from the private sector, from meta-analysis—will be excluded under the proposed criteria, even though they could be well-designed and carefully conducted, providing valuable insights. At the same time, the EPA has not articulated a strategy for working with researchers to release otherwise unpublished data on relevant issues.

Equally problematic is that while the rule requires the EPA to use “high-quality studies,” the rule doesn’t define “high-quality,” nor can it draw on widely agreed upon operational criteria for determining quality. Issues of cost, benefit, and the challenge of consent also go unconsidered.

“We recognize data sharing is important and the United States should continue to pursue broader data sharing,” reads the ASA statement. “But it should not be at the cost of restricting the science that EPA can use to fulfill its mission to protect the environment and the health of the US population.”