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Those interested in the linear no-threshold debate might be interested in a new rule being proposed by the Environmental Protection Agency (EPA). Strengthening Transparency in Regulatory Science is identified as Docket ID: EPA-HQ-OA-2018-0259-0001. One specific section of the proposed rule is of particular interest:
". . . this proposed regulation is designed to increase transparency of the assumptions underlying dose response models. As a case in point, there is growing empirical evidence of non-linearity in the concentration-response function for specific pollutants and health effects. The use of default models, without consideration of alternatives or model uncertainty, can obscure the scientific justification for EPA actions. To be even more transparent about these complex relationships, EPA should give appropriate consideration to high quality studies that explore: a broad class of parametric concentration-response models with a robust set of potential confounding variables; nonparametric models that incorporate fewer assumptions; various threshold models across the exposure range; and spatial heterogeneity. EPA should also incorporate the concept of model uncertainty when needed as a default to optimize low dose risk estimation based on major competing models, including linear, threshold, and U-shaped, J-shaped, and bell-shaped models."
The EPA is accepting public comment on this rule until 30 May 2018, and anybody who is so inclined is encouraged to submit comments by clicking on a button on the regulations.gov website.
