261 



Moreover, there are substantial doubts about the linear extrapolation method 

 used in calculating environmental health risks to the general public from the 

 miners studies. The linear extrapolation method is widely criticized by scientists; 

 that is, the process of inferring from occupational studies of uranium miners ex- 

 posed to radon at extremely high levels, the adverse health effects on the general 

 population exposed to low levels of radon in homes or schools. 



u'^^^J^u^'^ °^ certainty about the presence of a risk and the point at which that risk 

 should be actionable are equally vague when viewing the totality of the internation- 

 al literature. There are dozens of scientific studies of the health risks of radon in 

 the United States, Canada and throughout Europe that are no more conclusive than 

 the miners' studies. Further, the level of radon at which concern is voiced is sub- 

 stantially higher in other countries— levels of 12 to 20 picoCuries per liter (pCi/liter) 

 m Canada and Europe. Whereas, the United States has just suggested reducing "the 

 action level" 50 percent: from four to two pCi/liter. 



In addition, there is scientific disagreement over the threat posed by radon to chil- 

 dren. EPA has contended, based on a controversial statistical model, that children 

 are three times as susceptible as adults. But another study — of miners in China- 

 shows that exposure under the age of 13 may build something akin to an immunity 

 response. A current thought is that there is no additional risk due to early expo- 

 sure. Consequently, the age factor remains an uncertain factor — possibly contribut- 

 ing to a higher threat or more possibly reducing or not affecting the serious threat 

 of lung cancer. 



A literature review contracted by the EPA and the National Cancer Institute, re- 

 viewed 15 studies on radon and found that the studies were contradictory. Seven 

 studies found "statistically significant positive associations between estimated expo- 

 sure to indoor radon and lung cancer, six found no association and two found signifi- 

 cant negative associations." 



Former EPA Administrator William Reilly's March 1992 statement to the House 

 Committee on Science, Space and Technology was a broad indictment of EPA's lack 

 of scientific basis for it's policy pronouncements. This statement was based on EPA's 

 Science Advisory Board's recent report to upgrade the agency's scientific capability 

 and credibility. NSBA commended Administrator Reilly for his candid assessment of 

 the agency's need for an uncontrovertible base in scientific research before millions 

 of taxpayer dollars are spent to solve an alleged environmental problem. 



Developing a firm scientific basis for knowing that we have an environmental 

 hazard and the degree to which it should be abated are critical to EPA's credibility 

 and to ensure that education funding is spent wisely — either to protect the health of 

 children or to educate them. I believe that public policy was made ahead of the sci- 

 entific evidence on asbestos. The result was that millions of scarce educational dol- 

 lars were wasted. I believe that schools cannot afford to abate questionable environ- 

 mental hazards, abate them in an unnecessary way or abate them down to a level 

 that exceeds the scientific evidence on risk assessment. 



The issue of accurate risk assessment should be addressed before EPA is elevated 

 to a cabinet-level agency. 



Prepared Statement of Richard L. Hembra 



Mr. Chairman and Members of the Committee: 



We appreciate the opportunity to present our views on the creation of a Depart- 

 ment of the Environment and on Senate Bill 171. 



We are pleased to see that attention is still focused on creating a Department of 

 the Environment and that you have again introduced legislation to this end. As we 

 said in testifying on predecessors to S. 171," we believe that conferring Cabinet 

 status on the Environmental Protection Agency (EPA) would not only enhance the 

 status of environmental protection issues on the Nation's agenda but also enable the 

 Nation to respond more effectively to the complex environmental challenges it 

 faces. 



In summary, we continue to support the creation of a Cabinet Department of the 

 Environment for the same reasons that we have cited in the past. These reasons 

 include: 



' Creation of a Department of Environmental Protection (GAO/TRCED-89-52, June 21, 1989) 

 and Creation of a Department of the Environment GAO/T-RCED-90-26, Feb. 8, 1990). 



