Testimony of Dr. John Dale Dunn to the Human Health Risk Assessment Subcommittee
My concern is that EPA research repeatedly violates the Reference Manual rules on
observational study relative risk as proof of causation and the rules on toxicology. I think
well established and reliable scientific rules should govern EPA research.
The Manual insists on Relative Risk of at least 2 for proof of causation in observational
studies. The EPA sponsored and funded research repeatedly and flagrantly violates that
rule and claims small effects are reliable.