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Below is my public comment to EPA regarding its selection of members for the Clean Air Scientific Advisory Committee (CASAC)…

I am submitting comments concerning candidates for CASAC, as requested on May 10, 2021.

I have both general comments related to the panel member selection process and specific comments on candidates.

In summary:

  • Strive for balance and objectivity. The law requires CASAC to be balanced in terms of points of view. Prior to 2017, CASAC had devolved into a system cronyism where CASAC members with nearly identical viewpoints often reviewed and rubberstamped the results of their own or their colleagues’ EPA-funded research. There also exists the problem of certain candidates (e.g., individuals who have received tens of millions in EPA research grants) having undue influence over more junior colleagues.
  • Avoid financial conflicts of interest. EPA should avoid selecting candidates with a financial relationship with the agency. This principle should exclude those candidates who have received or otherwise benefitted from one or more research grants from EPA within the past five (5) years. Moreover selected candidates should agree in writing to not seek, accept or help their institutions obtain research grants from EPA during the next five (5) years.
  • No candidates who have participated or benefitted from unethical or illegal research. A number of the candidates for CASAC have conducted, participated in or have benefitted from affiliation with unethical/illegal human clinical experiments with air pollutants. No one who is associated with these unethical/illegal human experiments should be permitted to serve on CASAC.

While it is impossible to describe and proscribe all forms of potential corruption among CASAC members, EPA should strive to select an ethical and honest panel that represents varying points of view and where no panel member is intimated by others.

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