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FORCES - Evidence by topic - Back to: Proving the lies of the anti-tobacco cartel: The Evidence



In 1992, when the EPA was finished with its report on second hand smoke, and before publication, the Institution submitted the report to the EPA's Office of Research and Development Environmental Criteria and Assessment.

FORCES has come in possession of this review, which was not meant for publication.

Read it yourself. Like the preceeding expose` (Text of EPA epidemiologist's review of "EPA Report" on passive smoking), this is dynamite reading. We have highlighted in blue the critical parts.

Once again, one can see evidence of the disagreement within the EPA's own organization about classifying second hand smoke as a class A carcinogen. Once again, the comments of the reviewer are about sloppiness, inaccuracy, data spin doctoring, and the great rush to push it through.

The EPA's study on Passive Smoking -- as we well know by now -- is still the target for negative critique by many serious professionals around the world. The link between Environmental Tobacco Smoke and any disease is STILL TO BE PROVEN. It is still in the hands of biased statisticians, corrupted politicians, spin doctors, and corrupted or obtuse exponents of the medical profession. And considering the infinitesimal levels of pollutant emissions created by ETS, it will always be.


Text of EPA Office of Research and Development's review of the "EPA Report" on passive smoking

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
ENVIRONMENTAL CRITERIA AND ASSESSMENT OFFICE

CINCINNATI, OHIO 45268

March 24, 1992

SUBJECT: OHEA-C-361 - Respiratory Health Effects of Passive Smoking: Lung Cancer and Other Disorders

FROM: Terry Harvey, D.V.M., Director

TO: Linda Bailey-Betch, Technical Information Staff, OHEA (RD-689)

Attached you will find ECAO-CIN's evaluations of the documents identified above that you sent us on March 11, 1992 and requesting comments by today (verbally confirmed by Bill and Jeanette).

The primary requests of ECAO-CIN on page 2 of Bill's memo of March 9, 1992 have been satisfied by Pat Murphy (3/23) and Rick Hertzeberg's (3/21) attached reviews.

As you will note from the comments, no one liked the 11 day time allotted for review and thus a very quick product is attached as best we could accomplish in the time available. I suggest the document manager(s) consider more time for evaluation to balance the seriousness of this document as applied to the public health and the intrinsic value of doing it right on this key health topic.

I have personally reviewed only the "Summary and Conclusions" and have these comments:

1. I am concerned with the extrapolation of data from females to males in the married, never smokers (p. 1-3). There are sex differences for both cancer and non-cancer health effects. I suggest clarification of this variable to affirm inadequate male data and reinforcing the EPA cancer guideline proviso where inadequate data exists.

2. It is confusing to the reader to skip back and forth from "EIS" to "passive smoking" (pg. 1-1). I suggest an improved scientific description is "PETS" or "Passive Exposure To Tobacco Smoke." In any case, use one set of terms and define it upon first usage.

3. To be technically accurate and avoid confusion, the document summary (pg. 1-1) should not use the generic term "cancer" unmodified as to the type the causal effects have been clearly shown based on histological malignancy type, e.g., squamous cell carcinoma vs. adenocarcinoma. Great confounders will emerge if this is not carefully articulated (see Pat Murphy, Pg. 5). If you can technically show causal association, do; where you can't, don't infer it.

4. The non-cancer asthma effect must be clarified medically to show effects primarily in a sensitive asthmatic subpopulation having pre-disposition component-like genetic risks and not displayed as public health risk to the general non-predisposed population.

5. I suggest a full discussion of category A vs. B, based on the absence of definitive data on PETS in humans. Like it or not, EPA should live within its own categorization framework or clearly explain why we chose not to do so. You may wish at some stage to present this assessment to CRAVE to obtain Agency consensus and assure wider peer review.

ECAO-CIN will be most happy to spend further time improving the quality of this document. Let us know how we can be of further help.

cc: W. Farland (RD-689)
J. Wiltse (RD-689)

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