Not the Time to Reinvent EPA Science

In “Transforming How the Environmental Protection Agency Does Science”(Issues, Fall 2024), Terry F. Yosie exclusively promotes the use of One Environment-One Health and systems-based approaches for science. These approaches may sometimes work, but our knowledge is often inadequate to employ them and they are not applicable for every circumstance. EPA’s current approaches to science have been effective and need not be cast aside at this time. The future for EPA science must consider budget cuts and scientific integrity policies that recognize the separation between research and policy.

The health of both people and ecosystems in the United States has vastly improved because EPA conducts and uses science for decisionmaking. EPA scientists together with scientists in other agencies, academia, and the regulated communities contributed to the knowledge used by EPA to achieve these gains. Childhood lead poisoning provides a good example. The mean blood lead level for US children under age five in 2018 was 55% of the level in 2004 and just 4% of the level in 1972. This reduction did not result from command-and-control regulations or a narrow focus on a single source of lead exposure. The underlying research was conducted by hundreds of scientists across dozens of institutions. The resulting actions reduced lead in gasoline, food, water, air, and soil—and ultimately in homes, workplaces, play areas, and, critically, children.

Since EPA’s enactment in 1970, novel technologies involving new or reemerging environmental challenges have been the rule rather than the exception. Applying a systems approach to a known “system” and an identifiable “agent” has in some instances been successful. Still, we should not limit ourselves to this approach when the system or agent cannot be adequately described. A One Environment-One Health approach helps to explain, for example, the biotransformation from elemental/inorganic mercury to methyl mercury and its increasing concentration up the food web. It isn’t needed, however, to prohibit releasing any hazardous substance into the nation’s water, air, or food supply.

The elements of Yosie’s four-step road map are valuable—and EPA employs them to some degree. The agency’s effort to establish Alternative Test Methods and Strategies is a good example. Innovation, collaboration, and communication can, and should, be increased, especially with the public, academia, and regulated communities. However, such efforts hardly depend on a One Environment-One Health or systems-based approach to science.

Now is not the time to reinvent EPA science. The agency’s science budget has been stable for several years, at roughly $486 million. But a sharp decrease could be on its way, with some observers worrying that the incoming Trump administration will reduce the science budget to $263 million, the level it had previously proposed for 2020. A cut this size would greatly diminish EPA’s research programs. It would cut off grants, cap innovation, limit collaborations, freeze the pipeline of future researchers, and encourage needed senior scientists to take early retirement.

The agency’s scientific integrity policy, supported by all EPA administrators since 2012, ranks among the best across federal agencies. All employees, including political appointees, are required to follow the policy when engaging in, managing, or communicating scientific information. It recognizes that policy decisions are made not only on the best available scientific information but also on practicality, economics, and societal impact. The challenge will be to maintain a culture where the best science flourishes and policy decisions that may not align with research findings are accurately communicated to the public.

Thomas Sinks