The EPA Uses Children (and Adults) as Guinea Pigs

The United States Environmental Protection Agency (US EPA) has been involved in a scandalous, unethical, and illegal human exposure experimental research program for two decades. 

The Agency has sponsored, encouraged and funded research that exposes children and adults to air pollution, which it has told the congress and announced to the public is toxic, lethal, even cancer causing. 

During the 2000s, U.S. Environmental Protection Agency-funded researchers at Southern California Medical Schools sprayed high doses of diesel exhaust particles up the noses of 10-15 year old children in a ‘scientific’ experiment to see what would happen.  Federal and California State laws prohibit such immoral and  unethical experiments with children or even adults.  Does the EPA disregard and disrespect law and ethics in a mindless crusade to regulate air?

Although specifically required to do so by federal regulations and the Nuremberg Code-based California state law — if not basic morality — the University of Southern California (USC) and University of California, Los Angeles (UCLA) researchers failed to disclose to the children and parents of those children that the EPA, at the time had concluded that diesel exhaust emissions contained particles that are toxic, dangerous, deadly and cause cancer.

Since 1997, the EPA has regulated the small airborne particles (dust, called PM2.5) that are 95% of diesel engine emissions.  The theory was that the exhaust could cause death, even in a short-term exposure.

1998, the California Air Resources Board determined that any exposure to diesel exhaust could cause cancer.

In 2004, the US EPA determined that any exposure to PM2.5 could cause death within hours of inhalation. EPA’s official characterization of PM2.5 essentially renders it one of the most toxic, lethal and cancer causing air pollution substances known to man. 

After evidence of these illegal human exposures to small particle air pollution experiments in Southern California Medical Research facilities was discovered in 2012 by Steve Milloy of Junk, the EPA tried to delete the evidence from its publicly available Internet archives. Then it appears that they terminated the research program on children as too sensitive.   The agency had nothing to worry about, however, since politicians, pubic officials, even licensing boards, and, of course, the lapdog media, have not noted or criticized the conduct.  The activities are funded with millions from the do-no-wrong US EPA, after all.   

The human exposure experiments program of the US EPA dates to the early 1990s and is intended to develop evidence that various air pollutants cause serious health problems. I say “is” because the program is still ongoing at present and dates at least to 1996 when a college co-ed guinea pig at the University of Rochester died as the result of a procedure related to a human exposure experiment from a complication of a diagnostic procedure.  

A report of one of the research projects at the University of North Carolina School of Medicine in Chapel Hill attracted the attention of, but it was discovered in litigation that other  universities and their faculties around the country are involved in the unethical and inhumane exposure experiments,  including, by admission of EPA official Eugene Cascio, MD, Medical Schools at Rutgers, Ohio State, Michigan, Michigan State, Washington (State) U, UCLA, USC, and the Lovelace Medical affiliated with the U of New Mexico.

These Medical Schools and research groups have engaged in human exposure experiments for more than 10 years, receiving grants of more than 8 million dollars.

The American Tradition Institute (ATI, now called the Energy and Environmental Legal Institute) sued the EPA in 2012 to stop an ongoing experiment. After a round of procedural wrangling, the judge dismissed the suit, holding that ATI didn’t have the standing to protect the human study subjects. Only the study subjects themselves had the standing to sue. But since EPA had lied to the study subjects about the risks of the exposures in the experiments, how would they even know their legal rights had been violated?

When considering the potential for scandal considering the history of Nazi and other human experiments, you might ask why a United States Federal Agency like the US EPA is sponsoring and even conducting these experiments in the first place. After all, EPA already regulates the air pollutants at issue to the maximum and arbitrarily with little resistance ratchets down the acceptable air standards until industry and business suffer compliance costs that are enormous, so the EPA cannot really need human exposure evidence to add to its admittedly weak epidemiological research that it says proves up its case for pollution controls.

You might say, "what is their problem? They already have control and a no limits permission to regulate any air pollutant as much as they want."

The answer to the question was revealed in a declaration to the Federal Court under penalty of perjury by the EPA official in charge of the human experiments project at the University of North Carolina School of Medicine, Dr. Robert Devlin, PhD, and chief US EPA Scientist on the project.  He justified the human exposure experiments where diesel emissions were pumped into chambers for the guinea pig humans because the population (epidemiological) studies used by the US EPA didn’t prove that air pollution was toxic

The human experiments project was intended to fill in the void of evidence for toxicity of air pollutants.

Dr. Devlin admitted that the epidemiological studies are and were inadequate to draw any conclusions about whether small particle air pollution is biologically or medically —causing the deaths claimed by the EPA in its public statements.  So Dr. Devlin explains that the EPA has attempted to close gap and prove up their case against air pollutants by conducting experiments exposing humans to high levels of PM2.5 and other air pollutants.

In his declaration Dr. Devlin said (excerpts):

I was acting National Program Director for ORD's (Dunn: US EPA Office of Research and Development) Air Research Program in 2000.  This position is the lead for developing research plans related to air pollution for all of ORD and representing the program to groups outside the EPA.  I hold adjunct faculty appointments at the University of North Carolina (Chapel Hill) and North Carolina State University.  I have been engaged in performing controlled human exposure studies as an EPA investigator since 1986.   I have authored or co- authored more than 190 scientific articles, 53 of which involved controlled exposure of human volunteers to air pollutants. 

Epidemiological observations are the primary tool in the discovery of risks to public health such as that presented by ambient PM2.5.  However, epidemiological studies do not generally provide direct evidence of causation. They indicate the existence or lack of a statistical relationship between ambient levels of PM2.5 and adverse health outcomes.  

Controlled human exposure studies conducted by EPA scientists and EPA funded scientists at multiple universities in the United States fill an information gap that cannot be filled by large population studies.  In 1998 the Committee on Research Priorities for Airborne Particulate Matter was established by the National Research Council in response to a request from Congress.  The committee was charged with producing four reports over a five-year period which describe a conceptual  framework for an integrated national program of particulate-matter research and identified the most critical research needs linked to key policy-related scientific uncertainties.

My review of the US EPA air pollution human exposure research shows they have found no human exposure experimental evidence to bolster their claims.  In fact the one report that caught our attention that was reported in  the sponsored on line Journal Environmental Health Perspectives (EHP) was a pathetic report indeed, and not proof at all of air pollution toxic effects.  The woman was alleged to be an important case of air pollution cardiac effects was not healthy and had cardiac abnormalities before and discovered after she had a cardiac arrhythmia when exposed to air pollution.

What is amazing to me, as a physician, is that the US EPA persists in human exposure experiments with ozone and small particles after more than 2 decades with no evidence of air pollution toxicity, research still being funded by the EPA.  Also, with no lab evidence of toxicity they continue to toot loudly about the results of their weak and silly, small association, epidemiological population studies.  I assure the reader that if there was any good evidence of human toxicity from human exposure experiments with air pollution, it would be well publicized. 

In another era, the EPA officials responsible for these human exposure experiments would be in jail after losing their jobs and medical licenses.  In addition institutions would be subject to serious civil and even criminal charges as complicit in human experiments on children and adults, in violation of the Common Rule and all known ethical prohibitions.  Medical School Institutional Review Boards would be under investigation for complicity in the perfidy.

I have written about this problem to all the 18 Republican physicians in the congress but have received not once response or inquiry.  These are all licensed physicians who are, by their licensure, obligated to take action to prevent public harm by other practitioners.  They are also obligated by their public positions as Congressmen.

I have also written to State Medical Boards in North Carolina and Michigan, for example, about this scandal and the Deans of the 10 Medical Schools that do human exposure experiments, according to EPA officials.  Not one letter of response or indication of concern has been received.  

You might ask, "well it’s always about politics and money, isn’t it? And medical schools depend on funding, generous funding from the federal government."

John Dale Dunn MD JD is a main poster/blogger at, an inactive lawyer and is a member of the Faculty of an Emergency Medicine Residency. is a web site that focuses on integrity of scientific inquiry and the effect of politics and political corruption on those inquiries.   For much more information, go to the web site and do an appropriate subject word search. The materials and documents on the subject of human testing and EPA misconduct now are on the website in gigabytes.