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From: TSS ()
Subject: Interference at the EPA - Science and Politics at the U.S. Environmental Protection Agency
Date: May 1, 2008 at 6:52 pm PST

Reports and Research

Interference at the EPA

Science and Politics at the U.S. Environmental Protection Agency

The U.S. Environmental Protection Agency (EPA) has the simple yet profound
charge "to protect human health and the environment." EPA scientists apply
their expertise to protect the public from air and water pollution, clean up
hazardous waste, and study emerging threats such as global warming. Because
each year brings new and potentially toxic chemicals into our homes and
workplaces, because air pollution still threatens our public health, and
because environmental challenges are becoming more complex and global, a
strong and capable EPA is more important than ever.

Yet challenges from industry lobbyists and some political leaders to the
agency's decisions have too often led to the suppression and distortion of
the scientific findings underlying those decisions—to the detriment of both
science and the health of our nation. While every regulatory agency must
balance scientific findings with other considerations, policy makers need
access to the highest-quality scientific information to make fully informed
decisions.

Concern over this problem led the Union of Concerned Scientists (UCS) to
investigate political interference in science at the EPA. The investigation
combines dozens of interviews with current and former EPA staff, analysis of
government documents, more than 1,600 responses to a survey sent to current
EPA scientists, and written comments from EPA scientists.

The results of these investigations show an agency under siege from
political pressures. On numerous issues—ranging from mercury pollution to
groundwater contamination to climate change—political appointees have edited
scientific documents, manipulated scientific assessments, and generally
sought to undermine the science behind dozens of EPA regulations.

These findings highlight the need for strong reforms to protect EPA
scientists, make agency decision making more transparent, and reduce
politicization of the regulatory process. Congress, the next president, and
the next EPA Administrator must restore independence and scientific
integrity to the EPA by:

Protecting EPA Scientists: Scientists should be free to report the
distortion, manipulation, and suppression of their work without fear of
retribution. Congress should pass a whistleblower law that includes
protection for scientists. The EPA should adopt a communications policy that
lets scientists speak freely to the press about their findings. Making the
EPA More Transparent: Too many decisions are made behind closed doors with
little accountability. The EPA’s scientific findings should be freely
available to the public. The EPA should open up its decision-making process
to congressional and public scrutiny to help reveal misuses of science
Reforming the Regulatory Process: The White House should not change
scientific findings in order to weaken, delay, or prevent new public
protections. Ensuring Robust Scientific Input to EPA's Decision Making: The
EPA should review and strengthen how it uses the scientific expertise of its
staff and external advisory committees to create policies—especially when
scientific input is critical or required by law. Depoliticizing Funding,
Monitoring, and Enforcement: Problems with funding, monitoring and
enforcement also need to be addressed by Congress and the next President to
ensure that the EPA is the robust environmental agency that our country
needs. Political interference is not unique to the EPA. Use the links on
this page to explore surveys of scientists at other federal agencies and
scores of examples of the abuse of science on issues ranging from
prescription drugs to endangered species.

Program Overview Political Interference in Science Restoring Scientific
Integrity Stay Informed

Sign up for our online action networks or electronic newsletters. Enter your
email address for a list of options.

Contents Scientist Statement on Scientific Integrity 2008 Statement:
Scientific Freedom and the Public Good Evidence of Political Interference
Report: Interference at the EPA Report: Federal Science and the Public Good
Examples of Political Interference in Science Surveys of Scientists at
Federal Agencies Focus on Climate Science Focus on Endangered Species
Science more... News & Views Scientific Integrity Update--01/2008 Scientific
Integrity in the News Editorials on the Misuse of Science Poll: The Public's
Belief in Independent Science Science, Evolution, and Intelligent Design
Resources & Information Info for the Media Info For Congressional Staff
Scientific Integrity Curriculum Guide Other Groups Addressing Scientific
Integrity Science Idol: The Scientific Integrity Editorial Cartoon Contest

The Report Press Release Executive Summary (PDF) Interference at the EPA:
Full Report (PDF) FAQ's about the Report (PDF) Essay Responses From
Scientists Select Quotes (PDF) All Essays (PDF) Survey of EPA Scientists
Survey Summary and Supporting Documents Congress Reacts Letter to EPA from
Rep. Waxman (CA) Statement by Senator Whitehouse (RI) Statement by Rep. Holt
(NJ) Other Resources EPA and the White House (PDF) Air Pollution and the EPA
(PDF) Climate Change and the EPA (PDF) Toxics and the EPA (PDF) Focus on
Region 4 (PDF) Focus on Region 9 (PDF) Related Information Take Action
A-to-Z Guide to Political Interference

http://www.ucsusa.org/scientific_integrity/interference/a-to-z-alphabetical.html


Executive Summary

snip...

The Bush administration’s direct abuse of science—combined with systemic
changes to the regulatory system that threaten the in- tegrity of EPA
science—highlight the need for strong action by the next president and Con-
gress to restore scientific integrity to the agen- cy’s decision making.
Only then can the EPA fully mobilize to serve the public good and ensure the
nation’s health.

Report: Federal Science and the Public Good

http://www.ucsusa.org/scientific_integrity/interference/interference-at-the-epa.html


*************************************************************


April 29, 2004 (Supercedes March 2, 2004 memorandum) Consideration of Prions
as a Pest under FIFRA

http://www.epa.gov/oppad001/records_of_decision_on_prions.pdf


CHAMBER OF COMMERCE OF THE UNITED STATES OF AMERICA WILLIAM L. KOVACS 1615 H
S TREET , N.W. VICE PRESIDENT WASHINGTON , D.C. 20062 ENVIRONMENT ,
TECHNOLOGY & (202) 463 5457 REGULATORY AFFAIRS December 22, 2005

Likewise, some agency records of decision, as well as internal memoranda,
establish precedent for regulatory policy making that at times extend the
regulatory reach of federal agencies far beyond the statutorily mandated
powers given by Congress. A recent example of a record of decision with
regulatory impact would be the EPA’s decision to regulate prions.4 Prions
are protein structures which, when infectious, are suspected of causing
transmissible spongiform encephalopathy diseases, such as mad cow disease in
cattle.5 EPA’s decision to classify prions as “pests” under FIFRA stems from
an internal agency memorandum asserting jurisdiction over prions,6 even
though prions are not living things (a prerequisite for EPA jurisdiction
under FIFRA).7 Moreover, acting under the authority granted to itself in
this memorandum, EPA issued emergency exemptions to several states to
authorize the use of pesticides not registered under FIFRA to treat
prioninfected surfaces. Therefore, EPA is treating this memorandum as though
it is the issuance of a rule, without providing notice to the public or the
opportunity to comment on the agency’s interpretation of its authoritative
scope.8 The U.S. Chamber specifically requested EPA publish its prior
discussion in the Federal Register for notice and comment, but EPA did not
respond to that request. 3 Letter from Robert P. Murphy, General Counsel,
General Accounting Office, to The Honorable David M. McIntosh, U.S. House of
Representatives, January 20, 1999. 4 S.B. Hazen, Memorandum “Consideration
of Prions as a Pest under FIFRA” to the Record, April 29, 2004; accessed at:
http://www.epa.gov/oppad001/records_of_decision_on_prions.pdf. 5 See
definition of prion at http://en.wikipedia.org/wiki/Prion. 6 Memorandum from
Susan B. Hazen, Principle Deputy Assistant Administrator, to the record,
dated April 29, 2004. The memorandum is available on EPA’s Web site at:
http://www.epa.gov/oppad001/records_of_decision_on_prions.pdf. 7 7 U.S.C.
136(t). 8 The Administrative Procedure Act defines a “rule” as … an agency
statement of general or particular applicability and future effect designed
to implement, interpret, or proscribe law or policy…5 U.S.C. 551(4).

snip...full text ;

http://www.whitehouse.gov/omb/inforeg/good_guid/c-commerce.pdf


Rulemaking to Establish Criteria for the Importation of Designated Ruminants
and Ruminant Products From Canada into the United States Final Environmental
Assessment, December 2004

While FSIS recommends the use of disinfectants, EPA regulates disinfectants
under FIFRA. Prior to 2003, prions were not considered pests, and therefore
their treatment with disinfectants was not regulated. In September of 2003,
EPA classified prions as a pest (Hazen, 2004) and, therefore, the agency was
required to regulate the “microorganisms” under the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA).

http://www.aphis.usda.gov/newsroom/hot_issues/bse/background/documents/03-080-3%20environmental%20assessment.pdf


BSE; MRR; IMPORTATION OF LIVE BOVINES AND PRODUCTS DERIVED FROM BOVINES
[Docket No. APHIS-2006-0041] RIN 0579-AC01

[Federal Register: January 9, 2007 (Volume 72, Number 5)] [Proposed Rules]
[Page 1101-1129] From the Federal Register Online via GPO Access
[wais.access.gpo.gov] [DOCID:fr09ja07-21]

http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064801f8152


BSE; MRR; IMPORTATION OF LIVE BOVINES AND PRODUCTS DERIVED FROM BOVINES
[Docket No. APHIS-2006-0041] RIN 0579-AC01 Date: January 9, 2007 at 9:08 am
PST


http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064801f3412


PLEASE NOTE, THESE EPA DOCKET URLS ON MY SUBMISSION TO Importation of Whole
Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 ARE NO
LONGER GOOD ???

Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1]
RIN 0579-AB93 TSS SUBMISSION


http://docket.epa.gov/edkfed/do/EDKStaffItemDetailView?objectId=090007d480993808

http://docket.epa.gov/edkfed/do/EDKStaffAttachDownloadPDF?objectId=090007d480993808

http://docket.epa.gov/edkfed/do/EDKStaffCollectionDetailView?objectId=0b0007d48096b40d

Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL
IMPORTS FROM CANADA


https://web01.aphis.usda.gov/BSEcom.nsf/0/b78ba677e2b0c12185256dd300649f9d?OpenDocument&AutoFramed


Sent: Monday, July 24, 2006 1:09 PM

To: FSIS RegulationsComments

Subject: [Docket No. FSIS-2006-0011] FSIS Harvard Risk Assessment of Bovine
Spongiform Encephalopathy (BSE)

http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf


IN A NUT SHELL ;

(Adopted by the International Committee of the OIE on 23 May 2006)

11. Information published by the OIE is derived from appropriate
declarations made by the official Veterinary Services of Member Countries.
The OIE is not responsible for inaccurate publication of country disease
status based on inaccurate information or changes in epidemiological status
or other significant events that were not promptly reported to the Central
Bureau,

http://www.oie.int/eng/Session2007/RF2006.pdf

$$$ Science abused at the EPA $$$


Greetings,

I will be taking part in this action. Please be on the lookout for my letter
to an EPA scientist. I would further like to add to the ;

A-to-Z Guide to Political Interference

http://www.ucsusa.org/scientific_integrity/interference/a-to-z-alphabetical.html


BOVINE SPONGIFORM ENCEPHALOPATHY TYPICAL AND ATYPICAL BOTH OF WHICH HAVE
BEEN FOUND IN NORTH AMERICA.

The FDA/USDA et al have failed the public terribly in surveillance, testing,
and mad cow feed ban. all of which were/are fraught with errors, time and
time again, to a point of great suspicion $

and to add insult to injury, they have blatantly lied and covered up mad cow
disease and other TSEs, to a point of finally after 5 years of request after
request, they have officially denied my F.O.I.A. request for the final time.
They tell me if i want that info on those mad sheep of mad river valley in
Vermont, they tell me ;

"As FOIA requires an agency only to produce responsive non-exempt records to
a requester, OIG is not obligated to answer questions regarding the TSE
occurrence as you requested. Therefore, I am denying your appeal with
respect to your questions."

Mr. Terry S. Singeltary, Sr. Page 3

"For these reasons, I am denying your FOIA appeal. This is the final agency
decision. You may seek judicial review of this decision in the United States
district court for the judicial district in which you reside or have your
principal place of business or in the District of Columbia, pursuant to 5
U.S.C. & 552(a)(4)(B)."

please see full text ;

Thursday, April 24, 2008

RE-FOIA OF DECLARATION OF EXTRAORDINARY EMERGENCY BECAUSE OF AN ATYPICAL
T.S.E. OF FOREIGN ORIGIN IN THE UNITED STATES [Docket No. 00-072-1]

http://foiamadsheepmadrivervalley.blogspot.com/2008/04/re-foia-of-declaration-of-extraordinary.html


NOR-98 ATYPICAL SCRAPIE 5 cases documented in USA in 5 different states USA
2007

http://nor-98.blogspot.com/


Friday, April 25, 2008

Substances Prohibited From Use in Animal Food or Feed [Docket No.
2002N-0273] (Formerly Docket No. 02N-0273) RIN 0910-AF46

http://madcowfeed.blogspot.com/2008/04/substances-prohibited-from-use-in.html


Wednesday, April 16, 2008

REPORT ON THE INVESTIGATION OF THE ELEVENTH CASE OF BOVINE SPONGIFORM
ENCEPHALOPATHY (BSE) IN CANADA

http://madcowtesting.blogspot.com/2008/04/report-on-investigation-of-eleventh.html


BSE BASE MAD COW TESTING TEXAS, USA, AND CANADA

http://madcowtesting.blogspot.com/


Sunday, March 16, 2008

MAD COW DISEASE terminology UK c-BSE (typical), atypical BSE H or L, and or
Italian L-BASE (please note the last two mad cows documented in the USA, in
Texas and Alabama were both atypical BSE. please note, atypical BSE is more
virlent than typical BSE.

http://bse-atypical.blogspot.com/2008/03/mad-cow-disease-terminology-uk-c-bse.html


PLEASE SEE THE LARGEST EVER LONG TERM LIVE CASE STUDY WITH OUR CHILDREN
BEING EXPOSED TO MAD COW DISEASE IN THE NATIONS SCHOOL LUNCH PROGRAM, but
does anyone in the USDA/FDA et al even care to follow them $$$


DOWNER COW SCHOOL LUNCH PROGRAM

http://downercattle.blogspot.com/

http://downercattle.blogspot.com/2008/02/transcript-technical-briefing.html


[Docket No. 03-025IFA] FSIS Prohibition of the Use of Specified Risk
Materials for Human Food and Requirement for the Disposition of
Non-Ambulatory Disabled Cattle

9/13/2005

http://www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-2.pdf


Creutzfeldt-Jakob Disease (Variant) and Bovine Spongiform Encephalopathy
(Prion Diseases) Description Since 1996, strong evidence has accumulated for
a causal relationship between ongoing outbreaks, primarily in Europe, of a
disease in cattle called bovine spongiform encephalopathy (BSE, or “mad cow
disease”) and a disease in humans called variant Creutzfeldt-Jakob disease
(vCJD). Both disorders, which are caused by an unconventional transmissible
agent, are invariably fatal brain diseases with incubation periods typically
measured in years (1). Transmission of the BSE agent to humans, leading to
vCJD, is believed to occur via ingestion of cattle products contaminated
with the BSE agent; the specific foods associated with this transmission are
unknown. However, a recently published case-control study involving 132 vCJD
cases in the United Kingdom (UK) showed evidence of an increased risk for
vCJD associated with the frequency of consuming beef products likely to
contain mechanically recovered meat and head meat (such as burgers, meat
pies, and sausages) (2). Bioassays and molecular tests have enabled
identification of what World Health Organization consultants have classified
as “high-infectivity” and “lower infectivity” tissues of cattle with BSE
(3). The high-infectivity tissues include the brain, spinal cord, retina,
optic nerve, and dorsal root and trigeminal ganglia, suggesting that these
tissues can pose a relatively high risk of transmission. The lower
infectivity tissues include peripheral nerves (e.g., sciatic and facial
nerves), tonsils, nictitating membrane (third eye lid), distal ileum, bone
marrow, and possibly thigh muscle. The latter tissue from one cow with BSE
transmitted disease to highly BSE-sensitive transgenic mice at a rate
indicative of trace levels of infectivity.

http://wwwn.cdc.gov/travel/yellowBookCh4-VariantPrions.aspx


Progress Report from the National Prion Disease Pathology Surveillance
Center April 3, 2008

Progress Report from the National Prion Disease Pathology Surveillance
Center

An Update from Stephen M. Sergay, MB, BCh & Pierluigi Gambetti, MD

April 3, 2008

Dear Member:

Once again we are writing to thank you for your continued support in
enhancing surveillance of prion diseases in the United States and to bring
you up to date on the National Prion Disease Pathology Surveillance Center
(NPDPSC).

In large part because of your support, the number of cases examined by
biopsy, autopsy and 14-3-3 protein determination has increased significantly
over the years (see Tables 1 and 2). We are now able to establish a
definitive diagnosis of prion disease in an estimated 60-70% of the cases in
the United States, a percentage which exceeds that in even some major
surveillance centers. In addition, we receive from you cerebrospinal fluid
(CSF) for 14-3-3 determination, a surrogate protein which is helpful in the
diagnosis of prion disease, probably in most if not all cases of suspected
Creutzfeldt-Jakob disease (CJD). We are making constant efforts to reach our
goal of at least 80% definitively diagnosed cases.

The major obstacle to our further increasing the autopsy rate remains the
inadequate reporting of suspected cases of CJD to the NPDPSC or to the State
Health Department, which in turn would notify us. Since you are the one
likely to request the 14-3-3 test on these cases, please include in your
request the information needed to contact you, which we will do if the test
proves positive. If your institution uses a referral laboratory to send us
the CSF, please provide your name, phone, and fax numbers to the lab, which
will in turn submit it to us along with the sample. If this information is
missing in the request accompanying the CSF sample (as it happens in about
30% of the cases), we will be unable to contact the caregiving physician.
Having your contact information would also allow us to send results directly
to you, thus reducing turnaround times. ...

snip...

Prion surveillance in cattle has been reduced by 90% (from about 470,000 to
40,000 in the U.S. in 2007 out of about 35 million cattle slaughtered).
Termination of human prion surveillance would therefore remove the second
line of surveillance, thereby eliminating prion surveillance in the U.S.
entirely. This development would be extremely worrisome in view of recent
reports that precautions to limit the spread of the prion infectious agent
may not have been followed in some slaughter houses in the U.S. Cattle
affected with bovine spongiform encephalopathy (BSE) continue to be
discovered in Canada, which has more rigorous BSE surveillance than the U.S.
At the same time, Canada imposes few limitations in the trade of potentially
prion-infectious cattle with the U.S.

snip...

Atypical forms of BSE have emerged which, although rare, appear to be more
virulent than the classical BSE that causes vCJD.

please see full text with additional comments and links @ ;

http://prionunitusaupdate2008.blogspot.com/


CJD USA


*Acquired in UK ** Acquired in Saudi Arabia *** Includes 17 inconclusive and
9 pending (1 from 2006, 8 from 2007. **** Includes 17 non-vCJD type unknown
(2 from 1996, 2 from 1997, 1 from 2001, 1 from 2003, 4 from 2004, 3 from
2005, 4 from 2006) and 36 type pending (2 from 2005, 8 from 2006, 26 from
2007).

Notes:

-- Cases are listed based on the year of death when available. If the year
of death is not available, the year of sample receipt is used.

-- Referrals: Cases with possible or probable prion disease from which brain
tissue or blood in the case of familial disease were submitted.

-- Inconclusive: Cases in which the samples were not sufficient to make a
diagnosis.

-- Non-vCJD type unknown are cases in which the tissue submitted was
adequate to establish the presence but not the type; in all cases, vCJD
could be excluded.

-- Communicated by: Terry S. Singeltary Sr.

[In submitting these data, Terry S. Singeltary Sr. draws attention to the
steady increase in the "type unknown" category, which, according to their
definition, comprises cases in which vCJD could be excluded. The total of 26
cases for the current year (2007) is disturbing, possibly symptomatic of the
circulation of novel agents. Characterization of these agents should be
given a high priority. - Mod.CP]

http://www.promedmail.org/pls/askus/f?p=2400:1001:6833194127530602005::NO::F2400_P1001_BACK_PAGE,F2400_P1001_PUB_MAIL_ID:1010,39963


There is a growing number of human CJD cases, and they were presented last
week in San Francisco by Luigi Gambatti(?) from his CJD surveillance
collection.

He estimates that it may be up to 14 or 15 persons which display selectively
SPRPSC and practically no detected RPRPSC proteins.

http://www.fda.gov/ohrms/dockets/ac/06/transcripts/1006-4240t1.htm

http://www.fda.gov/ohrms/dockets/ac/06/transcripts/2006-4240t1.pdf


JOURNAL OF NEUROLOGY

MARCH 26, 2003

RE-Monitoring the occurrence of emerging forms of Creutzfeldt-Jakob

disease in the United States

Email Terry S. Singeltary:

flounder@wt.net

I lost my mother to hvCJD (Heidenhain Variant CJD). I would like to

comment on the CDC's attempts to monitor the occurrence of emerging

forms of CJD. Asante, Collinge et al [1] have reported that BSE

transmission to the 129-methionine genotype can lead to an alternate

phenotype that is indistinguishable from type 2 PrPSc, the commonest

sporadic CJD. However, CJD and all human TSEs are not reportable

nationally. CJD and all human TSEs must be made reportable in every

state and internationally. I hope that the CDC does not continue to

expect us to still believe that the 85%+ of all CJD cases which are

sporadic are all spontaneous, without route/source. We have many TSEs in

the USA in both animal and man. CWD in deer/elk is spreading rapidly and

CWD does transmit to mink, ferret, cattle, and squirrel monkey by

intracerebral inoculation. With the known incubation periods in other

TSEs, oral transmission studies of CWD may take much longer. Every

victim/family of CJD/TSEs should be asked about route and source of this

agent. To prolong this will only spread the agent and needlessly expose

others. In light of the findings of Asante and Collinge et al, there

should be drastic measures to safeguard the medical and surgical arena

from sporadic CJDs and all human TSEs. I only ponder how many sporadic

CJDs in the USA are type 2 PrPSc?

http://www.neurology.org/cgi/eletters/60/2/176#535


THE PATHOLOGICAL PROTEIN Hardcover, 304 pages plus photos and illustrations.
ISBN 0-387-95508-9

June 2003

BY Philip Yam

CHAPTER 14 LAYING ODDS

Answering critics like Terry Singeltary, who feels that the U.S. under-
counts CJD, Schonberger conceded that the current surveillance system has
errors but stated that most of the errors will be confined to the older
population.

http://www.thepathologicalprotein.com/


SRM MAD COW RECALL 406 THOUSAND POUNDS CATTLE HEADS WITH TONSILS KANSAS

http://cjdmadcowbaseoct2007.blogspot.com/2008/04/srm-mad-cow-recall-406-thousand-pounds.html

SPECIFIED RISK MATERIALS

http://madcowspontaneousnot.blogspot.com/2008/02/specified-risk-materials-srm.html


10 Million Baby Boomers to have Alzheimer's in the coming decades 2008
Alzheimer’s disease facts and figures

http://betaamyloidcjd.blogspot.com/2008/03/association-between-deposition-of-beta.html

re-Association between Deposition of Beta-Amyloid and Pathological Prion
Protein in Sporadic Creutzfeldt-Jakob Disease

http://betaamyloidcjd.blogspot.com/2008/04/re-association-between-deposition-of.html

Alzheimer's and CJD

http://betaamyloidcjd.blogspot.com/


Terry S. Singeltary Sr. P.O. Box 42 Baycliff, Texas USA 77518


Tuesday, April 29, 2008

Interference at the EPA - Science and Politics at the U.S. Environmental
Protection Agency

please see full text ;

http://sciencebushwhacked.blogspot.com/




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