There is nothing illegal about doing research on human subjects. All of the proper procedures were followed. No human subject was harmed.
Steven Milloy’s lawsuit is for pure political circus. He seems to be making a statement about the discrepancy between the EPA’s declaration that exposure to particulates is “lethal” (it is not; it *may* marginally increase the likelihood of death of a person with respiratory illness) and that they consider such exposure so benign that they fund human studies on it.
Many people would say that the EPA is going too far with air pollution standards, and the particulate standards is one area. Do you really want the EPA to ban fireplaces and barbecues, which are a couple of sources of particulates? Because that’s what people like Lisa Jackson want when they testify how “lethal” these particles are.
While I agree with the statement Milloy seems to make here, I do not agree with his methods. He’s a good blog writer. He should have stuck with writing a blog highlighting how the EPA grossly exaggerates dangers to increase their regulatory power, while their own policies show they don’t consider these risks significant.
Milloy is a biostatistician and a lawyer.
EPA says that PM 2.5 kills 570,000 people per year. They say it can kill you within hours of exposure. They say there is no safe exposure.
This must be the most toxic substance known to man based on what they say.
All the new standards you are talking about are based on this. Even the mercury rules are based on cost benefits from the reduciton of PM 2.5 and not mercury.
Now if this is true...why are they exposing people to 3.5x what the EPA is lethal?
They were not told that the PM 2.5 could kill them...thus this was not voluntary. EPA violated the law in this regard. Also they are supposed to do experiments on animals first. They did not. They violated all the human testing rules.
Now here is the big trap that I think Milloy is pointing out.
If EPA states that no person was exposed to deadly levels of PM 2.5 then there is no justificaiton for the Mercury MACT, the new NAAQS standards, etc. If they say it IS deadly then they violated not only their own rules (EPA order 1000.17)but also the common rule and the rules handed down after the Nuremburg trials.