Re: If you do Science, use the Scientific Method!

[BLHamrick@AOL.COM]

In a message dated 9/25/2003 6:02:05 PM Pacific Standard Time, sjd@swcp.com 

writes:

"This may seem silly, but is it possible that the EPA people who drafted

the NESHAPS did not understand that the LNT was a regulatory 'tool' and not

scientific fact?"



    It may seem silly, but in this corrupt day and age it wouldn't surprise me

at all.  More and more, and 'most everywhere you look, silliness appears to

be the reigning philosophy.

I also think this is entirely possible.  My understanding is that there are a 

dearth of actual HPs in EPA's Superfund program, and that even in the Office 

of Radiation and Indoor Air, there are probably too few spread too far.  



This means that many of the decisions are made by "policy" guys, with degrees 

in Political Science, Economics, etc. and crash courses in radiation and 

hazardous materials, with insufficient input from technical experts.  I suspect 

this is also why there are vast differences in policy at the operational level 

across EPA regions.  Policy in technical areas must have significant input from 

the technical experts, otherwise it cannot be implemented in any logical and 

consistent way at the operational level.



For all the grief NRC takes, it is my experience that they have a much better 

handle on their day to day operations than the EPA, much more oversight of 

their regions, and much more consistency across the country.



Bad science makes bad policy, but not enough science can make it too, or even 

make it worse.



Barbara