In last night’s Republican debate, the candidates were asked if they could eliminate just one federal agency, which one would it be? Herman Cain chose the EPA:
The first — the first department, if I were forced to eliminate a department, I would start with the EPA and start all over. It’s out of control.
Now, I know that makes some people nervous, but the EPA has gone wild. The fact that they have a regulation that goes into effect January 1, 2012, to regulate dust says that they’ve gone too far.
So rather than try to fix it, eliminate all of the things that they have right now and then start rebuilding a responsible EPA.
Mother Jones jumped on the dust claim, calling it a “myth”:
Yes, the EPA is revisiting its dust standards—but those standards have been in place since 1987. In April, the EPA issued an evaluation of particulate matter pollution standards, because the report is a requirement under the Clean Air Act. And while the report suggested that dust standards should be tightened, the EPA has no plans to “regulate” dust any time soon.
In other words, the EPA already regulates dust and will “revisit” and “tighten” those regulations because the Clean Air Act mandates that they do. But saying the EPA wants to regulate dust is to speak a “myth.”
The EPA is concerned about “fine particulate matter“, or PM2.5, which are particles “less than 2.5 micrometers in diameter” and are “referred to as ‘fine’ particles and are believed to pose the greatest health risks. ”
One of the main constituents of health-risky PM2.5 is—are you ready?—dust. Dust? Dust is everywhere! My Goodness: What about the children! They’re on it: “One group at high risk is active children because they often spend a lot of time playing outdoors and their bodies are still developing.”
The key word above is “believed.” Why does the EPA “believe” dust poses “health risk”? The same way the EPA believes a lot of things: by relying—heavily—on the ecological fallacy, a statistical faux pas and leading generator of epidemiological over-certainty.
Last week we looked at a paper which announced the following distressing finding (the extensive criticism is here):
Cardiovascular disease (CVD) deaths, especially those from ischemic heart disease (IHD), are consistently and robustly associated with measures of fine particulate and traffic-related air pollution.
The sentence is plain and does not need much interpretation: fine particulate (PM2.5) and traffic-related air pollution is killing people.
Why did the authors make this claim? They must have designed some sort of experiment whereby people in various stages of health were gathered and the amount of dust that they inhaled over some period of time was measured. This might have involved CAT scans, in situ measurements of dust both in the air and in the lung, and so forth. Since one puff of dust probably isn’t deadly, these folks would have to be followed for a considerable time.
Just measuring dust would not be enough, of course. They’d have to measure, for every individual, their health and health history. Probably competent doctors, say, or nurses asked questions like, “Do you have heart disease? Does it run in your family?”, etc. Some people would be dead from heart attacks, so to ascertain whether the dust killed them, autopsies would have had to be performed.
Complicated business! But the health of children is involved, so no expense must have been spared. Yet did the authors actually do this?
No. Instead, the authors used a statistical model that first guessed where that person lived (at one time), then used another model to guess how much dust was in the air nearby where that person lived, then tried to see if these people died from heart attacks or suffered from other ailments. The model said, “Not significant!”, so they kept trying models (about a dozen of them) until they found one which gave them statistical “significance.”
The authors then invoked that miracle of certainty, the environmental fallacy. This fallacy (roughly) states that correlations are equivalent to causations. An (old) example might be to notice that in certain geographic areas ice creams sales are correlated with drownings. The EPA would use this correlation to say, “Ice cream causes drowning” and so seek to regulate it.
Never did the authors actually undertake any measurement that would allow them to make the claim CVD is “consistently and robustly associated with measures of fine particulate.” I stress that dust could cause CVD and other diseases, but the authors offered only tepid and error-ridden circumstantial evidence. Further, they offered no competitive theories for what might have caused the deaths they noted. Thus, the also fell pray to the “I can’t think of an alternate explanation so there isn’t one” fallacy.
Since this is only one of a legion of ecological-fallacy papers on which the EPA relies, Herman Cain was on to something when he suggested we scrap the EPA and start it again from scratch.