EPA as a public health agency

Our plain-English summary of EPA as a public health agency, by B.D. Goldstein (Regulatory Toxicology and Pharmacology, 1988).

The study

• Author: B.D. Goldstein
• Journal: Regulatory Toxicology and Pharmacology
• Published: 1988;8(3):328-34
• Cited by: 4 articles, as counted by NIH iCite
• Read it: PubMed · Publisher

Abstract

Much of EPA's actions are driven by concerns for public health. The public's perception of the potential adverse consequences to their health of chemical and physical agents in the general environment is a common motivating force in setting EPA's agenda and in making regulatory decisions. Despite its responsibilities in public health, and the major role that public health plays in its decision making, EPA is not part of the Department of Health and Human Services, the federal cabinent-level department with primary responsibility for human health. Rather, EPA is an independent agency with its own Administrator who is the decision maker for over a dozen legislative acts, many of which are based on public health concerns. For very few of these laws is there more than a minimal tie to the activities of classic public health agencies in the Department of Health and Human Services. Unfortunately, this organizational approach has led to a relative lack of individuals trained in the discipline of public health which hinders EPA's ability to approach public health problems. While there are many good reasons to keep EPA a separate entity from the Department of Health and Human Services, it is imperative there be close cooperation between EPA and the appropriate units of the U.S. Public Health Service. Most importantly, the number of people within EPA who are trained in public health disciplines must be increased. As a corollary there must be a concerted effort to educate students in a manner responsive to the need for public health manpower at EPA and at State and local agencies active directly or indirectly in environmental health issues.

In plain English

This article is a commentary, not a research study. The author served as EPA Assistant Administrator for Research and Development from 1983 to 1985. Drawing on that experience, the author argued that the U.S. Environmental Protection Agency had too few staff trained in public health. EPA began in 1970 with 5791 employees, 650 of them Commissioned Officers. At the time of writing it had close to 14,000 employees, including about 240 U.S. Public Health Service commissioned officers. Asbestos in schools was one of three examples. The author wrote that EPA's early rules almost completely ignored the dangers of ineffective asbestos removal. Part of the response was a model risk assessment that assumed 10 equal schools. The model assumed that asbestos risk fell by 99% in 9 of them, and that in 1, poor removal practices caused a 10-fold increase in asbestos exposure. The calculation showed the total risk for the 10 schools would be worse than doing nothing. EPA then moved toward sharing information locally and checking quality rather than policing. The other examples concerned gasoline fumes and priority setting. The author concluded that EPA needs more employees trained in public health.

We wrote this plain-English summary from the full article with the help of AI, and a second AI model checked each sentence against the article. It is not the authors' wording; the abstract and the article are their own account.

What the study did and found

• Design: commentary based on the author's experience inside EPA; not a research study
• Who was studied: The U.S. Environmental Protection Agency and its staff: 5791 employees at its founding in 1970, close to 14,000 at the time of writing; the author's observations cover 1983 to 1985
• Exposure: Asbestos in schools (asbestos-containing materials that had become friable; fiber type not named), gasoline fumes at service stations including benzene, and the use of risk assessment to set agency priorities
• Main results:
  • The author stated that EPA's initial asbestos-in-schools regulations almost completely ignored the dangers of ineffective asbestos removal.
  • A model risk assessment assumed 10 equal schools. In 9, asbestos risk fell by 99%. In 1, poor removal practices produced a 10-fold increase in asbestos exposure. These figures are model assumptions, not measured data.
  • In that model, the total risk for the 10 schools would be worse than if nothing had been done in any of them.
  • EPA's Asbestos in Schools Program shifted toward spreading information at the local level and a quality assurance role rather than acting as a policeman.
  • For gasoline fumes at service stations, the author stated that a primary preventive option was considered on equal footing with a secondary preventive option.
  • The author argued that relying on risk estimates to set budget priorities would underfund primary prevention activities.
• The authors' conclusion: The author concluded that EPA does not have the instincts of a public health organization and should increase the number of employees trained in public health, while remaining separate from the Department of Health and Human Services.

Related studies

• An assessment of the Environmental Protection Agency's asbestos hazard evaluation algorithm — M.E. Findley, V.E. Rose, et al. (1983)
• Comparing epidemiologic studies of ingested asbestos for use in risk assessment — L.S. Erdreich (1983)
• EPA and asbestos removal — J. Berry (1990)
• Asbestos in drinking water: a status report — J.A. Cotruvo (1983)
• How do you interpret regulations: through science or agency rules? — J.H. Lange (2002)
• An air quality data analysis system for interrelating effects, standards, and needed source reductions: Part 13--Applying the EPA Proposed Guidelines for Carcinogen Risk Assessment to a set of asbestos lung cancer mortality data — R.I. Larsen (2003)

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