JunkScience Petitions White House For Epidemiology Standards – Juris Dr Steven J Milloy Speaks The Truth – 2018 02 20














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As long as I’ve been involved in federal regulatory issues ( since 1990 ), regulators have used JUNK EPIDEMIOLOGY to JUSTIFY OVER-REGULATION. 


For the first time ever, we have an administration that is committed to stopping OVER-REGULATION. 


So JunkScience.com petitioned the Trump administration today to stop the MISUSE AND ABUSE OF EPIDEMIOLOGY by issuing EPIDEMIOLOGIC STANDARDS for federal agencies.


The petition is below. 


Steve Milloy

Founder & publisher of the web-site called JunkScience.com 








February 20, 2018


President Donald J. Trump

The White House

1600 Pennsylvania Ave., N.W.

Washington, D.C.  20500


Re : Petition For Federal Standards To Stop Over-Regulation Based On Junk Epidemiology








Dear President Trump,



I am submitting this petition under the First Amendment right to petition the federal government to redress grievances. 


I request that you issue EXECUTIVE BRANCH-WIDE STANDARDS for the use of EPIDEMIOLOGY STUDIES by regulatory agencies. 


An alternative request is that you DIRECT REGULATORY AGENCIES to issue their own such STANDARDS via public notice and comment. 


Pending the issuance of such standards, regulatory agencies should be ordered to suspend all use of EPIDEMIOLOGY STUDIES pending review under the new standards. 


This petition is consistent with your initiative to REDUCE OVER-REGULATION that hurts the economy without providing commensurate or even any benefit. 


Just one example of the significance of the problem of JUNK EPIDEMIOLOGY is President Obama’s key War-On-Coal Regulations issued by the U.S. Environmental Protection Agency ( EPA ). 


As you know, these rules were responsible for destroying about 94 per cent of the market value of the Coal Industry and killing many thousands of Coal Industry jobs during the period 2011-2016 without providing any health, environmental or economic benefits whatsoever. 


The rules in question were « justified » on the basis of about $600 million worth of EPA-funded EPIDEMIOLOGIC STUDIES. 




You justifiably complain about « fake news ».  This petition would go a long way toward preventing the « fake news » that has been unjustifiably harming our economy and standard of living for decades. 








Petition To President Donald J. Trump For Federal Standards To Stop Over-Regulation Based On Junk Epidemiology





EPIDEMIOLOGY is the statistical study of the incidence of disease in human populations. 


Importantly, EPIDEMIOLOGY is merely a branch of statistics; it is NOT science. 


EPIDEMIOLOGY DOES NOT provide biological or medical explanations ( i.e., physical plausibility ) for its purported results. 


EPIDEMIOLOGY’s statistical nature is most useful when looking for high rates of rare disease in a population. 


The classic examples of properly applied EPIDEMIOLOGY are food poisoning incidents and the link between heavy smoking and lung cancer. 


Unfortunately, however, over-zealous regulatory agencies have been DISREGARDING THE LIMITATIONS OF EPIDEMIOLOGY for almost 30 years. 


They often pretend that EPIDEMIOLOGY is a complete science, NOT merely statistics. 


They often IMPROPERLY USE EPIDEMIOLOGY to study low rates of common diseases. 


The data used in EPIDEMIOLOGY STUDIES is often of such POOR QUALITY that epidemiologists REFUSE TO SHARE THEIR DATA with independent researchers for purposes of replicating and verifying results, a tradition fundamental to the scientific method. 


In the case of EPA’s War-On-Coal Rules, EPA-funded researchers have been HIDING DATA from public review for more than 20 years    even defying the request of EPA’s own statutorily mandated science advisory board and Congressional subpoena for the data. 


The ABUSE OF EPIDEMIOLOGY by federal regulatory agencies can be exemplified to laymen by comparing the number of deaths attributed to smoking against the number of deaths attributed to blue-sky clean air. 


The Department of Health and Human Services claims that smoking kills about 440,000 people per year. 


But the Obama EPA claimed that fine particulate matter ( soot and dust called « PM2.5 » ) in everyday blue-sky outdoor air kills 570,000 per year. 


So, smoking kills 440,000 while blue-sky outdoor air kills almost 30 per cent more on an annual basis ?!?! 


One can easily understand why the EPA-funded epidemiologists have been HIDING THEIR DATA for 20-plus years. 








Petition To President Donald J. Trump For Federal Standards To Stop Over-Regulation Based On Junk Epidemiology


Current Epidemiologic Standards In The Federal Government



The first effort to issue standards for interpreting EPIDEMIOLOGY STUDIES was articulated by famed British Epidemiologist Sir Austin Bradford Hill in 1965. 


Hill almost uncannily foresaw the most common ABUSE OF EPIDEMIOLOGY we see today    i.e., INAPPROPRIATE RELIANCE ON WEAK STATISTICAL CORRELATIONS ( also called « weak associations » ) that likely reflect only POOR DATA QUALITY OR CHANCE, versus meaningful results. 


The adage « correlation is not causation » should come to mind here. 


Not only is the adage true, but also WEAK CORRELATIONS ( or WEAK ASSOCIATIONS ) never portend causation. 


Weak associations are just meaningless, statistical noise. 


There is NOT a single example in the scientific literature of a WEAK ASSOCIATION EPIDEMIOLOGY STUDY whose reported association turned out to be scientifically valid. 


The Obama EPA used this STATISTICAL NOISE to unjustifiably wreak havoc on the Coal Industry.


While Hill’s criteria do appear in some agency guidance documents concerning the use and interpretation of EPIDEMIOLOGY, they uniformly omit Hill’s warning about the UNRELIABILITY OF WEAK ASSOCIATIONS. 


As a consequence, regulatory-happy federal agencies often disregard Hill’s standards and MIS-INTERPRET STATISTICAL NOISE as cause-and-effect relationships in order to justify their (over)regulatory agendas.


Though the federal courts have received some GUIDANCE on the interpretation of EPIDEMIOLOGY from the National Academy of Sciences and an international standards group ( Grading of Recommendations Assessment, Development and Evaluation or « GRADE » ) has issued some standards for interpreting EPIDEMIOLOGY STUDIES, federal regulatory agencies have remained oblivious and their MISUSE AND ABUSE OF EPIDEMIOLOGY is ongoing. 


Congress has also tried to rein in the ABUSE OF EPIDEMIOLOGY. 


The House-passed HONEST Act would require that EPIDEMIOLOGIC DATA relied on by EPA be MADE AVAILABLE TO THE PUBLIC for purposes of verification and study replication. 


Although the bill has passed the past three House sessions, it has been stranded in a Senate that requires 60 votes to pass a bill. 








Petition To President Donald J. Trump For Federal Standards To Stop Over-Regulation Based On Junk Epidemiology


The Lack Of Epidemiology Standards Threatens Efforts To Reduce Over-Regulation



It is a safe bet that virtually all EPIDEMIOLOGY-based federal regulatory efforts over the past 25 years or so may be considered as « fake science » or « junk science ». 


This is because federal agencies, especially the EPA, have taken actions or issued warnings or regulations based on the STATISTICAL NOISE that is WEAK ASSOCIATION EPIDEMIOLOGY. 


This « fake science » should be held up to NEW ROBUST FEDERAL EPIDEMIOLOGY STANDARDS, and then validated or discarded based on its actual merits. 


Otherwise, any de-regulatory agenda is at severe risk of failure or roll-back.


Consider the EPA’s proposed repeal of the Obama War-On-Coal rule known as the Clean Power Plan ( CPP ). 


Although the CPP is ostensibly a rule addressing greenhouse gas emissions, the Obama EPA actually justified the rule on the basis that reduced coal plant greenhouse gas emissions would necessarily mean reduced emissions of the afore-mentioned PM2.5 from coal plants. 


As the Obama EPA had determined ( BY SECRET SCIENCE-BASED WEAK ASSOCIATION EPIDEMIOLOGY ) that PM2.5 was associated with thousands of premature deaths annually ( each valued by EPA via JUNK ECONOMICS at about $9 million ), the CPP was « determined » by the Obama EPA to provide billions of dollars in benefits annually    an IMAGINARY AMOUNT OF BENEFITS that far exceeded the actual multi-billion estimated compliance costs of the CPP. 


The Trump EPA has proposed to REPEAL the Clean Power Plan ( CPP ) the basis that PM2.5 CAUSES NO DEATHS at current levels    essentially IGNORING THE FAKE SCIENCE of previous EPAs on PM2.5 . 


This more realistic view of PM2.5 reduced the CPP’s ESTIMATED AND IMAGINARY BENEFITS to well below its actual compliance costs. 


Reducing the Over-Regulation of all the PM2.5-dependent War-On-Coal Rules    including the Cross-State Air Pollution Rule and Mercury Air Transport Standard ( MATS )    requires a review of the PM2.5 EPIDEMIOLOGY under new standards. 


The Obama EPA’s onerous and benefit-less ozone air quality standards also depend on the PM2.5 FAKE SCIENCE. 


It would be possible to reduce that rule’s EXPENSIVE AND POINTLESS OVER-REGULATION by reviewing its underlying science under sound principles and standards for EPIDEMIOLOGY. 








Petition To President Donald J. Trump For Federal Standards To Stop Over-Regulation Based On Junk Epidemiology





EPIDEMIOLOGY has been GROSSLY ABUSED by regulators and university researchers for so long, the vast majority of epidemiologists NO LONGER CARE whether their work is charitably described as « GARBAGE-IN, GARBAGE-OUT ». 


That situation may be fine for AGENDA-DRIVEN REGULATORS and their GRANT-HUNGRY UNIVERSITY EPIDEMIOLOGISTS, but it is a terribly DESTRUCTIVE SITUATION for the economy, tax-payers and science. 


I am happy to answer any questions you may have.





Steve Milloy, MHS, JD, LLM


Trump EPA Transition Team member



















Background Information


Juris Dr Steven J Milloy’s Biography



Steven J Milloy is a Juris Doctor and a leading policy expert on the subject of regulatory affairs and pest control products. 


Dr Milloy is among several highly-rated leading experts who have recognized expertise, training, and background in matters concerning pest control products, and who promote environmental realism and pesticide truths.   http://wp.me/p1jq40-8DV  


He is also the founder and publisher of the web-site called JunkScience.com, the senior legal fellow at the Energy & Environment Legal Institute, and the author of Scare Pollution : Why and How to Fix the EPA. 


Dr Milloy also served on the Trump EPA transition team. 


He has also been the president of Citizens for the Integrity of Science, a long-time columnist for FoxNews.com, and the co-founder & portfolio manager of the Free Enterprise Action Fund, the first conservative/libertarian mutual fund. 


Juris Dr Milloy earned a B.A. in Natural Sciences from the Johns Hopkins University, a Master of Health Sciences in Biostatistics from the Johns Hopkins University School of Hygiene and Public Health, a Juris Doctorate from the University of Baltimore, and a Master of Laws from the Georgetown University Law Center. 


As one of the most effective and consistent spokesmen on the subject of public policy and pest control products, Juris Dr Milloy has effectively and consistently spoken out against fanatжcal-activists and their anti-pesticide prohibitions on a very frequent basis. 










The Wisdom of a REAL Expert


The Whole Truth From DR MILLOY Can Be Explored On The Pesticide Truths Web-Site 



















































Epidemiology is the statistical study of the incidence of disease in human populations.  Epidemiology CANNOT be relied upon alone, and must be backed-up with animal toxicity studies.  Epidemiology studies that identify potential associations must be confirmed with well-conducted animal toxicity studies that are specifically designed to elicit toxic effects over a series of dose levels.  These animal toxicity studies are assessed to determine if there is any biological basis for the potential associations noted in epidemiology studies.  The examination of animal toxicity studies from internationally-accepted guideline studies using doses well-above those to which humans are typically exposed, combined with exposure data obtained from well-designed studies, is currently a useful methodology available for assessing risks to human health.  Health Canada’s Pest Management Regulatory Agency ( PMRA ) undertakes this kind of assessment to supplement information about potential associations that may be established by epidemiology studies.  This approach is consistent with that of other regulatory authorities that base human health risk assessments on animal toxicity studies.

The classic examples of properly applied statistical epidemiology are food poisoning incidents and the link between heavy smoking and lung cancer.  For decades, left-wing fanatжcal government officials have been disregarding the near-worthlessness of statistical epidemiology.

Nonetheless, left-wing fanatжcal government officials conveniently avoid the fact that epidemiology is merely statistical analysis.  Statistical epidemiology is NOT science, and does NOT provide biological or medical explanations for its purported results.  Statistical epidemiology is most useful when looking for high rates of rare disease in a population.  Left-wing officials spread fake-news & junk statistical epidemiology for their own nefarious purposes.

Left-wing fanatжcal government officials have despicably exploited junk statistical epidemiology to justify the reckless & arbitrary prohibition against pest control products used in the urban landscape.  Just one example of the significance of the problem of junk statistical epidemiology is the legislation & imposition of Ontario’s Cosmetic Pesticides Ban Act.  As we all know, Ontario’s provincial prohibition has been responsible for destroying 100s of businesses and 1000s of professional jobs in the professional lawn care industry.    http://wp.me/P1jq40-238    Ontario’s prohibition, based upon junk epidemiology, led to catastrophic business & financial carnage, without providing any health, environmental or economic benefits whatsoever.    https://wp.me/P1jq40-43B

Junk statistical epidemiology relies on secret data, and have been either poorly or even fraudulently conducted & reviewed, as exemplified in the literature review concocted by Ontario College of Family Physicians ( OCFP ). Any competent literature review clearly demonstrates that pest control products are scientifically-safe, and WILL NOT cause harm to people, animals, or the environment.    http://wp.me/p1jq40-7HR    http://wp.me/P1jq40-2ha    http://wp.me/p1jq40-5ni    If a conventional pest control product actually caused cancer, it is fairly certain that this would be ascertained through the extensive testing procedures required before it is registered for use.  The idea that there is an epidemic of human cancer caused by synthetic industrial chemicals is NOT supported by either toxicology or statistical epidemiology.

OCFP is operated by discredited, radical, & scientifically ignorant mad-men pretending to be scientists, who are too lazy & too stupid to conduct a competent literature review.  Observers justifiably complain that OCFP spreads fake-news & junk statistical epidemiology that will unjustifiably harm our economy and standard of living for decades.  Not surprisingly, OCFP is a principal architect in the conspiracy to prohibit against pest control products used in the urban landscape.    http://wp.me/P1jq40-37C    In Ontario & elsewhere, left-wing fanatжcal government officials outrageously exploit junk statistical epidemiology as weapons of coercion and ultimate environmental terrжr in order to promote their pesticide-hating agendas.

Pest control products are scientifically-safe, and there is NO scientific basis for pesticide bans.  Statistical epidemiology is wrong, and nearly worthless for the assessment of pest control products.








Please explore the following link  


The Media Library On Epidemiology






















We Speak The Whole Truth With The Wisdom Of REAL Experts Like Dr Steven J Milloy



We are the National Organization Responding Against HUJE that conspire to destroy the Green space & other industries ( NORAHG ). 


NORAHG is a non-profit & independent organization that reports on the work of several highly-rated leading experts who have recognized expertise, training, & background in matters concerning pest control products, & who promote environmental realism & pesticide truths. 


NORAHG produces A Look At , a series of reports & blogs providing PRACTICAL INFORMATION on issues such as Career Management, Golf Course Maintenance, Green Alternatives, Lawn Care Maintenance, Summer Stress, Tree & Shrub Maintenance, Turfgrass Pests, & Turfgrass Species.


A Look At is destined for the green space industry, nation-wide across Canada, the United States, & overseas, & can be found on The Pesticide Truths Web-Site      http://pesticidetruths.com/  


A Look At is committed to SOUND SCIENCE, as well as ground breaking original reporting that informs, entertains, & creates real change.


All information, excerpts, & pictures contained in A Look At were retrieved from the Internet, & may be considered in the public domain. 


The information presented in A Look At is for preliminary planning. 


Before making a final decision, the turf manager is expected to obtain trusted expert advice from extension specialists, local distributors and/or agronomists. 


All decisions must take into account the prevailing growing conditions, the time of year, & the established management practices. 


All products mentioned in A Look At should be used in accordance with the manufacturer’s directions, & according to provincial, state, or federal law. 


For the official advantages, benefits, features, precautions, & restrictions concerning any product, the turf manager must rely only on the information furnished by the manufacturer. 


The mention of trade names does not constitute a guarantee or a warranty.


NORAHG also produces Force Of Nature, which dares to defy the pesticide-hating fanatжcs by exploring the whole truth from an independent perspective on The Pesticide Truths Web-Site      http://pesticidetruths.com/  


A Look At , Force Of Nature, & their various incarnations, was the brain-child of William H Gathercole ( now retired ) & his colleagues. 


Here is a brief summary of Mr Gathercole’s career 


FIELDS OF STUDY      Horticulture/Agriculture      Mathematics      Physics. 


ALMA MATER      McGill University      University of Guelph      the first person ever to obtain university degrees & contribute to both the professional lawn care & golf maintenance industries. 


EXPERTISE IN      turf & ornamental maintenance & troubleshooting      history of the green space industry      sales & distribution of seeds, chemicals, fertilizers, & equipment      fertilizer manufacturing & distribution      environmental issues & anti-pesticide terrжrism. 


NOTABLE ACTIVITIES      worked in virtually all aspects of the green space industry, including golf maintenance, professional lawn care, tree & shrub care, distribution, environmental compliance, government negotiations, public affairs, & workplace safety         the supervisor, consultant, &, programmer for the successful execution of hundreds-of-thousands of management operations in the golf course & urban landscape, as well as millions of pest control applications      the advisor, instructor, & trainer for thousands of turf & ornamental managers & technicians      the pesticide certification instructor for thousands of industry workers      a founder of the modern professional lawn care industry      the prolific writer for industry publications, reports, & blogs      the first to confirm the invasion of European Chafer insects in both the Montreal region & the Vancouver / Fraser Valley region      with Dr Peter Dernoeden, the first to confirm the presence of Take All Patch as a disease of turf in Eastern Canada      with Dr David Shetlar, the first to confirm the presence of Kentucky Bluegrass Scale as an insect pest in South-Western Ontario, & later, in the Montreal & Vancouver regions. 


SPECIAL CONTRIBUTIONS      the creator of the Exception Status that allowed the golf industry to avoid being subjected to anti-pesticide prohibition for a generation      the creator of the signs that are now used for posting after application      the co-founder of annual winter convention for Quebec golf course superintendents      the co-founder of the first ever Turf Summit      the major influence in the decision by Canadian Cancer Society to stop selling-for-profit fresh pesticide-treated daffodils      the only true reliable witness of the events of anti-pesticide prohibition in the town of Hudson, Quebec      the founder ( now retired ) of A Look At & Force Of Nature reports & blogs. 


NOTABLE AWARD      the first man-of-the-year for contributions leading to the successful founding of the Quebec professional lawn care industry, which served as a beach-head against anti-pesticide activists in the 1980s & 1990s. 


LEGACY      Mr Gathercole & his colleagues      designed & implemented strategies that reined anti-pesticide activists & provided peace & prosperity for the entire modern green space industry across Canada for a generation      orchestrated legal action against anti-pesticide activists in the town of Hudson, Quebec      launched the largest founding professional lawn care business in the nation      quadrupled the business revenues of one of the largest suppliers in the nation. 


Mr Gathercole is now retired, although his name continues to appear as the founder of A Look At & Force Of Nature reports & blogs. 


We dare to defy by exploring the whole truth from an independent perspective on The Pesticide Truths Web-Site      http://pesticidetruths.com/  


If you wish to receive free reports & blogs on issues that concern you, please contact us at      force.of.de.nature@gmail.com   WILLIAM H GATHERCOLE AND NORAH G