The Association of American Medical Colleges (AAMC), Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), and Council on Governmental Relations (COGR) submitted a joint response to the Environmental Protection Agency (EPA) regarding its Supplemental Notice of Proposed Rulemaking (SNPRM) for the rule “Strengthening Transparency in Regulatory Science.” While expressing a commitment to transparency and the use of best available evidence in policymaking, the associations criticize the proposed rule and its alternatives for advancing a flawed approach that would restrict the EPA's regulatory decision-making to studies whose underlying data are publicly available. They argue this requirement disregards the quality and merit of peer-reviewed science, could exclude important research, especially studies involving sensitive human data governed by legal and ethical protections, and would undermine evidence-based policy by tying the agency’s hands.
The associations further contend that public availability of data does not equate to scientific validity or reproducibility, and that the EPA already has mechanisms for evaluating which studies to consider, including expert review panels and comparative analysis. The proposed restriction could therefore impede the EPA’s capacity to fulfill its legislative mandate to utilize the “best available science” to protect human health and the environment. They note the rule also fails to recognize established safeguards for sensitive data and the fundamental purpose of scientific research, which is not exclusively conducted for regulatory decision-making. Concluding their remarks, the associations urge the EPA to rescind rather than revise the rule, underscoring that effective, evidence-based regulation requires allowing EPA scientists unimpeded access to the full range of relevant, high-quality scientific studies.
