Trump EPA Proposal Re Dose-Response Analysis Is Inappropriate And Not Scientifically Based Say Epidemiologists – Comment By Thursday Night 11:59 PM Eastern Time

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There is still time to comment by Thursday night, 1159 US Eastern Time (NY-DC time zone). It becomes public record https://www.regulations.gov/docket?D=EPA-HQ-OA-2018-0259 Docket ID: EPA-HQ-OA-2018-0259

Excerpt from “Comments of the International Society for Environmental Epidemiology on EPA’s proposed rule on Strengthening Transparency in Regulatory Science (EPA-HQ-OA-2018-0259-0001)

4. The EPA’s proposal in regards to dose-response analysis is inappropriate and not scientifically based EPA’s proposal details very specific criteria for judging what types of analyses provide valuable information about what concentration or dose-response curves look like, instead of relying on the judgment of the scientific community and its own science advisory committees. The proposal states “When available, EPA shall give explicit consideration to high quality studies that explore: a broad class of parametric dose-response or concentration-response models; a robust set of potential confounding variables; nonparametric models that incorporate fewer assumptions; various threshold models across the dose or exposure range; and…

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