On January 4, 1999, I posted a brief write-up titled "Environmental Working Group whines that probability is too hard." The posting spotlighted the EWG's complaint to the EPA about the use of Monte Carlo analysis in estimating pesticide exposures, as reported by the Daily Environment Report (1/4).
Later that day, I received this e-mail from Ken Cook, president of the EWG. To summarize the e-mail, Cook claimed that my posting was wrong and that EWG strongly supported the use of Monte Carlo analysis. Cook signed off my calling me an "arrogant little f*ck" -- sans asterisk.
Ostensibly, the EWG supports the use of Monte Carlo analysis, even to the point of using the method in its January 1998 report "Overexposed: Organophosphate Insecticides in Children's Food." The report claimed that "Every day, 1 million American children age 5 and under consume unsafe levels of a class of pesticides that can harm the developing brain and nervous system."
But I'm loathe to accept at face value anything the EWG claims, including its protestation in support of Monte Carlo Analysis.
In the context of estimating pesticide exposure, Monte Carlo analysis uses probabilistic and statistical methods to produce more realistic exposure estimates -- especially when compared to the EPA's traditional "upper-bound" estimates of exposure.
Because Monte Carlo analysis is likely to produce lower exposure estimates -- leading to lower risk estimates -- the method is likely to result in continued use of pesticides. This is not exactly the EWG agenda.
Thanks to a combination of EPA bureaucrats untrained and unwilling to learn the Monte Carlo method and those EPA staff who recognized the threat to the agency's current anti-pesticide goosestepping, Monte Carlo analysis has been methodlogy non grata at the EPA.
But over the last couple of years, the EPA appears to have changed its opinion of Monte Carlo analysis -- at least enough to request public comments regarding how the method should be used in estimating pesticide exposure.
With the handwriting on the wall, perhaps the EWG thought it had no choice but to embrace Monte Carlo analysis. The only question then would be how to game the system so that the anti-pesticide jihad could stay on track. And, apparently, EWG has figured out how to do just that.
As discussed in this posting, the EWG's analysis employed a bogus methodology -- using EPA reference doses (RfDs)for assigning relative potency values to different pesticides. RfDs are calculated by applying an arbitrary safety factor, ranging from 10 to 3,000, to a dose level that (typically) caused no harm to laboratory animals. Since the safety factor is based on subjective factors, it is not a valid basis for assigning relative toxicity among pesticides.
Sure the EWG is for Monte Carlo analysis -- when it can be cooked to give an answer that advances the EWG's extreme anti-chemical agenda. For my money, real arrogance is the EWG trying to pass off its nonsense as a valid Monte Carlo analysis.
Finally, and in the spirit of name calling, I don't call him "Ken Kook" for nothing.
Comments on this posting?
Click here to post a public comment on the Trash Talk Bulletin Board.
Click here to send a private comment to the Junkman.
Copyright © 1998 Steven J. Milloy. All rights reserved on original material. Material copyrighted by others is used either with permission or under a claim of "fair use." Site developed and hosted by WestLake Solutions, Inc.
Material presented on this home page constitutes opinion of Steven J. Milloy.