WARNING: This site deals only with the corporate corruption of science, and makes no inference about the motives or activities of individuals involved.
    There are many reasons why individuals become embroiled in corporate corruption activities - from political zealotry to over-enthusiastic activism; from gullibility to greed.
    Please read the OVERVIEW carefully, and make up your own mind.

OPINION ONLY

Approached to make Anti FDA comments COMMENTS TO THE DOCKET AND RELATED ACTIVITIES THINK TANK [TI16860638/0639]

1996 June: Candidates for Corrections Day: The Ten Worst Regulations of the Federal Government. This is a joint publication of the Alexis de Tocqueville Institution and the Institute for Policy Innovation. Note that most of the other chapters are written by notable 'friends of the tobacco industry'

• Senator Robert W Kasten Jr. Introduction [He was well supported by the tobacco industry and lobbied on their behalf]
• Johnathan Tolman — Wetlands Policy: The making of a Regulatory Frankenstein. [an environmental policy analyst with the Competitive Enterprise Institute]
• Loren Thompson — The 60 - 40 Rule , (a plea for more private enterprise in US Department of Defence supply) — Loren Thompson is Senior Fellow of the Alexis de Tocqueville Institution and teaches defense courses in the School of Foreign Service at Georgetown University. Also at the Lexington Institute.
• Michael Herson — Off-label Use Regulation . Attacking the FDA for not permitting the drug companies to promote their drugs for conditions where they have not been subject to normal testing procedures.
• John Berthoud — Special Education: Washington vs. The Children.
      Opposing US Department of Education (DoEd) rules that prevent schools from expelling 'special-education' students who have disciplinary problems.
      Also: Medical Devices and Drug Approval: Has FDA Improved its Performance? John Berthoud is Vice President of the Alexis de Tocqueville Institution and an adjunct lecturer in political science at George Washington University.
• Dave Juday — The US Peanut Program — opposed to farm subsidies for peanut growers. He was an Adjunct Fellow of the Alexis de Tocqueville Institution and a former chief agricultural policy advisor to Vice President Dan Quayle. [Also Hudson Institute]
• Merrick Carey — Environmental Tobacco Smoke: ideology Before the Facts. (Taking the tobacco line, wholesale.) Merrick Carey is President of the Alexis de Tocqueville Institution and was previously Press Secretary to Congressman Jack Kemp and Director of Intergovernmental Affairs for New Jersey Governor Thomas Kean.
• Michael Fumento — The Delaney Clause: Nostalia We Can't Afford. A perennial attack on the old rule of lowest-possible toxins in the environment. Michael Fumento is a science correspondent for Reason magazine and author of Science Under Siege : Balancing Technology and the Environment.
• Steven J ("Junkman") Milloy — President of the Environmental Policy Analysis Network, Inc , is a biostatistician, attorney and author, and specializes in health risk assessment issues He has written two Chapters.
  • Chapter 7: Glen Ridge Superfund Site.
     
        Glen Ridge in New Jersey had been placed by the EPA on its Superfun National Priorities List because it was discovered that the ground was contaminated by radioactivity from an old radium-watch-dial/instrument factory. It was also found to have high levels of indoor rado gas — up to 150 times normal levels. Residents were evacuated from their homes and unable to return until the clean up was completed.
    
        Milloy maintained that the standards set by the EPA for the cleanup were "Cadillac" and the amount of soil excavated was "excessive."

    The absence of observed lung cancers associated with the site may be explained by the fact that the EPA risk assessment for the site was more driven by overly-conservative EPA risk assessment policies than science.
    
        In fact, there is no scientific consensus that ambient or residential levels of radon are harmful to humans. That low levels of radon exposure pose a health risk is only an unsubstantiated theory propounded by regulatory officials under the guise of "better safe than sorry."

  • Chapter 9: Toxic Release Inventory (TRI) This attacks the EPA-administered Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 which was intended to inform the public when hazardous substances were spilled in their neightbourhood. About 600 chemicals were listed in the Toxic Release Inventory.
    
        The EPCRA had been enacted after the Bhopal, India accident, but his article was aimed at California's Proposition 64 which required public notification of the use of toxic chemicals. He wrote:

    If risk assessments were conducted for TRI chemicals, most, if not almost all, listings would likely not be warranted based on risks posed to human health or the environment. Only those chemicals that actually pose health and environmental threats would be subject to reporting. Unjustified listings produce no tangible public health or environmental benefits yet cause significant direct and indirect costs.

    At this time many large coalitions of industries, including the tobacco industry, were promoting the idea that 'risk assessment' was the solution to regulatory problems, since it would restrict the ability of the EPA, OSHA and FDA to promulgate rules which had an impact on their bottom lines.

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