The letter, jointly submitted by 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), expresses strong opposition to the Environmental Protection Agency’s (EPA) proposed rule requiring that only studies with publicly available underlying data be considered in regulatory decision-making. The associations, representing a broad spectrum of major U.S. research institutions, argue that this policy would hinder the EPA’s ability to utilize the best scientific evidence, particularly given legitimate ethical, legal, and privacy concerns that frequently limit data sharing—such as participant confidentiality in sensitive health studies. They emphasize that peer-reviewed studies, even without publicly accessible data, often maintain rigorous standards, and mechanisms exist within the scientific process to validate findings independently.
The signatories contend that the proposed rule misrepresents the recommendations of scientific organizations and journals, which generally do not advocate for excluding research lacking open data. They further highlight that the rule could conflict with existing federal regulations protecting certain types of information and would likely exclude key studies foundational to public health protections, such as those linking air pollution to mortality. The associations underscore their support for open science and data transparency but urge the EPA to abandon an approach that risks disregarding crucial, high-quality research. Instead, they advocate for collaborative policy development that balances transparency, privacy, and scientific integrity to ensure the use of the best available evidence in regulatory activities vital to human health and environmental protection.
COGR, along with the AAMC, AAU and APLU submit their joint letter to the Environmental Protection Agency (EPA) opposing a proposed rule that seeks to limit the scientific research it will consider unless all underlying data are made publicly available. The mechanisms of competitive grant funding and peer review of publications serve to ensure the validity of science and integrity of research even when the data are not available to the public for legitimate, reasonable and ethical reasons. Restrictions related to data availability, such as the privacy of individual health information should not discount the validity of the research, or its findings, and should not prevent the EPA from using credible research in its rulemaking decisions.
If instituted, the proposal will prevent the EPA from evaluating the best available evidence when making its regulatory decisions. Because of this, the cosigning organizations urged the withdrawal of the proposed rule and invite the EPA to engage with the scientific community to discuss how evidence-based policy should be developed to protect human health and the environment.
