The AAMC submitted comments on May 18 with the Association of American Universities, the Association of Public and Land-grant Universities, and the Council on Governmental Relations in response to the supplemental notice of proposed rule-making (SNPRM), “Strengthening Transparency in Regulatory Science,” issued by the Environmental Protection Agency (EPA). The groups asked that the agency withdraw the proposed rule and supplemental notice entirely.
The notice expands the scope of the proposed rule to include “influential scientific information” and proposes an alternative approach to regulatory decision-making that would allow the agency to give greater consideration to studies for which the underlying data is available for independent validation. Additionally, it expands the EPA’s ability to narrow the use of evidence in its rule-making decisions by discarding studies that are not yet final but may have significant implications for human health and the environment.
The AAMC submitted joint comments in 2018 opposing the original proposed rule, which would limit the EPA’s use of science in the rule-making process to those studies for which all underlying data were publicly available. The letter stated that, rather than encourage and facilitate data sharing, the rule would only have prevented the agency from considering all best available science when developing regulations aimed at protecting human health.
In the new letter, the associations argued that the value or merit of peer-reviewed science is not determined by the public availability of the underlying research data and that the rule would “tie the agency’s hands indefinitely.” The associations explained: “…Our member organizations take the need for evidenced-based policymaking and commitment to scientific integrity and transparency seriously, and we welcome the opportunity to assist the EPA in achieving those objectives. However, the proposed rule does not further those goals and should not be revised through the [SNPRM] but rather rescinded entirely.”