NTEU CHAPTER 280 - U.S. ENVIRONMENTAL PROTECTION AGENCY,  NATIONAL HEADQUARTERS
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NTEU E MAIL TO EPA ADMINISTRATOR ON ARSENIC REGULATIONS


We in NTEU Chapter 280 recognize management's right to set policy and
direction for the Environmental Protection Agency. We further recognize
that risk management necessarily and appropriately must consider the
economic and political feasibility of alternative courses of action. We
have no quarrel with that.

What we ask, though, and what the Agency's Principles of Scientific
Integrity mandate, is for EPA's leaders to be direct and candid when
announcing decisions for which the driving force was economic or political,
and not to resort to putting a veneer of "science" on those decisions, and
not to denigrate the work of competent and honest scientists whose
conclusions may be inconvenient.

An independent analysis of the science behind the proposed arsenic standard
has already been done. The National Academy of Sciences has looked at
arsenic in drinking water and published the findings in a book, Arsenic in
Drinking Water. The National Academy was unanimous in recognizing that
arsenic has adverse effects on health - at the current standard of 50
micrograms per liter.

The public policy debate over arsenic really should be about feasibility
and cost of clean up versus adverse effects avoided, and not about supposed
ambiguity over arsenic's adverse effects on health. We feel that framing
the issue as one of imprecise science is disingenuous, a violation of the
Priciples of Scientific Integrity and harmful to the Agency for which we
both work.

In Solidarity,

James J. Murphy, Ph.D., D.A.B.T.
President, NTEU Chapter 280