Assessing Toxicological Risks to Human Subjects Used in Controlled Exposure Studies of Environmental Pollutants

Published September 6, 2016

This document was submitted by John Dale Dunn, M.D., J.D., on August 24, 2016 to the National Research Council of the National Academy of Science on US EPA Scientific Misconduct in conjunction with oral testimony presented simultaneously. The testimony has been lightly edited and reformatted by the staff of The Heartland Institute with permission of the author.

Dr. Dunn and several other experts on pollution and human health were invited to submit testimony by the NRC as part of an investigation into potential wrongdoing by the Environmental Protection Agency (EPA). According to Dr. Dunn, EPA has been sponsoring experiments on human subjects involving exposures to small particle air pollution that EPA has declared publically and repeatedly to be toxic, lethal and even alleged it to be carcinogenic. This creates a dilemma for EPA: Either it broke the law by sponsoring human experiments forbidden under domestic and international law, custom and medical/scientific ethics, or it had repeatedly lied to Congress and the American people about the health threat of exposure to low levels of particulate matter.

Dr. Dunn writes, “I assert that ambient small particle air pollution is benign and isn’t killing anybody. In 45 years of medical practice I am still waiting for a death from small particle exposure. Unreliable epidemiology makes possible the scare about air pollution, but it is an empty vessel. Epidemiology is not junk science, it’s just limited to be less than proof of causation because it is so uncontrolled, but epidemiology can become deceitful if done without recognizing the limits of the methods and the uncertainties. I see this US EPA air pollution research project – that has been funded by billions, from mostly government sources – as a gigantic deceit, built on uncontrolled observational studies and projecting non-proof small associations to create big claims of deaths in particular.”

Dr. Dunn concludes his testimony with the following words: “The committee must ask, under what circumstances could these human experiments on minors be ethical or legal? The answer, surely, is “none,” unless EPA and its researchers walk back their claims that hundreds, thousands, even millions, of people are dying from exposure to ambient levels of small particle air pollution.

“How is that going to happen in this hyper political world? How can we achieve scientific integrity in a world where money and influence push science with a political agenda, and where so many scientists are motivated knowingly or unconsciously to lie for what they think is a just cause?

“The problem of scientific integrity is a big problem caused by “Big Science.” Milloy, Young and I are here to ask the committee to consider the violation of ethics, morality and the law committed by the human experiments promoted by EPA. We all fret about scientific integrity, but do we want to fix the problem? This is your opportunity to do so.”