Policy Documents

Testimony of Dr. John Dale Dunn to the Human Health Risk Assessment Subcommittee

John Dale Dunn MD JD –
November 14, 2007

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.