Steve Milloy is one persistent gentleman. Combining his legal and statistical education, he has spent most of his years ferreting out the false use of statistical techniques in the field of epidemiology. He continues the same quest in his latest book Scare Pollution: Why and How to Fix the EPA (2016) Bench Press. This is his sixth such book since Science-Based Risk Assessment: A Piece of the Superfund Puzzle (1995).
Just what is epidemiology? One definition: “the science concerned with the study of the factors determining and influencing the frequency and distribution of disease, injury, and other health-related events and their causes in a defined human population for the purpose of establishing programs to prevent and control their development and spread.” Milloy notes that “The key to the value of epidemiology as an investigative tool is that a researcher must be looking for a relatively high rate of a relatively rare event in a human population… Epidemiologic results are essentially correlations and, as we all learn in Statistics 101, correlations do not equate to causation.” The “devil is in the details” aphorism comes to life as Milloy exposes the EPA’s use of any minute level of correlation as evidence of statistically significant correlation to justify its definition of Clean Air standards.
Milloy’s latest book documents his multiple attempts in multiple formats to hold the EPA to basic standards of ethical epidemiologic theory and practice. His book details the quixotic nature of that quest.
An executive order by President Richard Nixon in 1970 unified federal environmental activities into a single new organization, the U.S. Environmental Protection Agency. Though the EPA was never officially organized by Congress as a presidential cabinet-level department, Nixon’s new federal bureaucracy undertook the writing and implementation of Clean Air Act (1970) laws. This unique status of the EPA as an all-powerful federal agency lacking cabinet-level status continues to the present. It has developed itself into a self-perpetuating rogue agency which defies congressional oversight attempts, as Milloy documents. From its $1 billion annual budget and 4,000 employees in 1970, the EPA expanded into a $6 billion annual budget with 16,000 employees by 1991.
Milloy began working on a variety of environmental issues involving the EPA in 1990. However, his quest for truth in statistics in identifying such impacts on human health has identified one issue at the top of the pile of EPA “malfeasance” actions. That is the matter of air quality standards.
Milloy: “When EPA began regulating PM in 1971, it regulated relatively large pieces of dust and soot that were anywhere from 25 to 45 millionths of a meter (one to two thousandths of an inch) in diameter. In 1987, EPA revised its rules to focus on smaller bits of dust and soot that were 10 millionths of a meter in diameter (about half the width of a human hair) — so-called PM10 (pronounced P-M-ten). In November 1996 under Administrator Browner, EPA proposed to regulate even smaller bits of dust and soot, particles that were 2.5 millionths of a meter in width — so-called PM2.5 (pronounced P-M-two-point-five).