EPA’s “Anti-Environment” Regulation Will Undermine the Reliability of Studies that will be Considered by EPA

As the August 16, 2018 comment deadline approaches, the public, including the editors of InternationalMosaic.com may have to accelerate their efforts. The substance of this morning’s comment is below.

Dr. Frank Kline, a psychiatrist who has taught at both the University of Southern California and the University of California, Irvine, said the following:

“Statement of Frank Kline, M.D.
August 13, 2018

“I am a psychiatrist who spent 13 years as professor at USC’s Medical School and 13 years as professor of psychiatry at the University of California at Irvine. I have served as a medical officer in the United States Army and have worked in public clinics. During my career, I have written and/or reviewed numerous papers, speeches, studies and books concerning biomedical research.

“Based on my experience it is my professional opinion that good medical studies often require that the identity of individual test subjects be kept confidential. Many test subjects refuse to participate in studies if they know that their identity and personal medical information will not be protected.

“Studies done on human subjects where the subjects’ privacy is not protected may produce false or biased results.”
Dr. Kline’s statement underscores the need to protect test subject privacy in all good biomedical research. The statement unveils the true folly of proposed regulation.

Equally important, the statement shows that the proposed regulation may warp future EPA regulations by forcing the EPA to turn a “blind eye” towards good scientific studies merely because the studies’ investigators protect the privacy of their test subjects. The adverse environmental impacts may be horrific and require full disclosure in the NEPA required EIS.

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