John A. Todhunter

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John A. Todhunter is a toxicology consultant who operates through his own organisation, Science Regulatory. Services International)

He previously served as Assistant Administrator of the Office of Pesticides and Toxic Substances (OPTS) at the Environmental Protection Agency (EPA) from the advent of the Reagan Administration in 1981 to March 1983 when he abruptly resigned, along with the EPA Administrator Anne Gorsuch, Deputy Administrator John Hernandez, and a number of other political appointees in key positions (Todhunter was one).

More than half of the federal regulations targeted for an early review by the Reagan administration's regulatory reform team were EPA rules. Virtually all of her subordinates at the EPA came from the ranks of the industries they were charged with overseeing.

The EPA-Reagan fiasco

Gorsuch had been handpicked by Joseph Coors and his Colorado associates in the Republican/Reagan kitchen cabinet. Her tenure enraged environmentalists, who tied her to the equally controversial policies of her friend and fellow Coloradan, then-Secretary of the Interior James Watt. Gorsuch's second husband, Robert Burford was a cattle baron who had vowed to destroy the Bureau of Land Management, and so President Reagan made him the Bureau's head.

Not to be outdone by her husband, Anne Gorsuch enthusiastically gutted EPA's budget by sixty percent, crippling its ability to write regulations or enforce the law. She appointed lobbyists fresh from their careers with paper, asbestos, chemical and oil companies to run each of the principal EPA departments. Her chief counsel was an ex-Exxon lawyer and ther head of enforcement came from General Motors, and virtually all of her subordinates at the EPA came from the ranks of the industries they were charged with overseeing.

Both Republicans and Democrats attacked her handling of the agency. Eventually, following a congressional investigation into sweetheart deals with polluters (including Coors), Gorsuch and twenty-three of her cronies were forced to resign (for misleading Congress), and her first deputy, Rita Lavelle, was jailed for perjury. . [A year later Reagan, seeking to reward a loyalist, appointed her to the chairmanship of the National Advisory Committee on Oceans and the Atmosphere].

In Todhunter's area of the EPA (according to Forbes magazine [1]), the cut-regulation-cabal was blamed for the slow pace of Superfund cleanups. In March 1983 they resigned under fire during a scandal over mismanagement of a $1.6 billion program to clean up hazardous waste dumps This was enforced after the botched handling (including document-shredding) of evacuation of Times Beach, Mo., a small community plagued by dioxin pollution., [See Risk Policy Report overview of the fiasco [[2]] in 1997]

The indictments and resignations put a temporary damper on Reagan's kitchen cabinet appointments, Joseph Coors and the Sagebrush Rebels ... but they quickly regrouped as the "Wise Use" movement. Coors then threw his political-leverage funds at Heritage Foundation and the Cato Institute, which became Washington's favourite 'libertarian' think-tank.

EPA Policy

During the transition period from Carter to Reagan, Todhunter spoke to a meeting of the American Industrial Health Council (the AIHC which was the Chemical Manufacturers Association's lobby organisation) on the subject of '"Science as the Foundation for Regulatory Decision-Making". [3] In this speech he emphasises that the general thrust.of the Reagan Administration and the regulatory team put together by Anne Gorsuch, (the new EPA Administrator), was to:

"... carry out the mandate of the laws which we are charged to administer and enforce, . including statutory deadlines and court ordered schedules and things of this type. However, in doing that we intend to take every possible effort to bring greater credibility to the science which is used in the decision-making and where possible to simplify the regulatory burden and reduce unnecessary costs to the public."

Among the changes he planned was to implement a scientific peer review system: "in order to avoid embarassing situations which have developed in the past," and to use" focused symposia on specific subjects in order to obtain and record comments from interested parties, particularly those from the scientific community." Todhunter summed up his overall objectives as:

"Our agency and our Office of Pesticides and Toxic Substances is very committed to improving what we do scientifically and to improving our credibility, and I don't think that the public is well served by being taken continuously through an emotional wringer by a lot of short-cut science. We've got to distinguish between real problems and hypothetical problems."

Pesticides (EDB)

From the previous Carter administration period he inherited a decision to take regulatory action to suspend the pesticide Ethylene Dibromide (EDB) ... but he declined to do so. Instead, he produced his own 'alternative' EDB risk assessment which downplayed the risk. According to one EPA insider, this consisted of "back of envelope calculations."

Edward Johnson, a director of the Office of Pesticide Products (OPP) of the EPA testified to Congress that this reassessment was "an example of Todhunter playing scientist [and that he] used poor methods". He had also asked Anne Barton, a statistician at the EPA, to alter her risk estimates for EDB using an "obscure scientific theory she had never seen before (or after)."

In 1983 the OPP had presented toxicological evidence on EDB saying that "they had never seen a substance that caused so many tumours so quickly" in laboratory animals. They recommended that, because of EDB groundwater contamination, the use of EDB for soil fumigant should be immediately suspended, and this was done as an emergency measure in the same year.

A 1997 issue of Risk Policy Review [4] says that through Todhunter's handling of the EDB issue:

"The news media were handed a juicy storyline that included unseemly official conduct, bumbling bureaucrats, and horrific public health threats contained in something as familiar as a bread wrapper.... [Competing agendas] filled the vacuum, whipping the public into a frenzy and further eroding trust and confidence in public institutions."


Todhunter also performed a highly controversial analysis of formaldehyde which the Office of Toxic Substances (OTS) had identified three years previously as a candidate for priority attention under the Toxic Substances Act. This new analysis deviated from known carcinogen risk analyses techniques, and it was said to rest "on a number of questionable assumptions." In the wake of these episodes the National Research Council recommended that the EPA develop formal risk assessment guidelines. [5]

Science Regulatory Services International

After leaving the EPA he helped establish Science Regulatory Services International, and began providing services to corporate clients. Between Oct 1990 and June 1992 he was one of a very large number of scientists recruited by the tobacco industry to provide critical comments on the EPA's attempts to regulate passive smoking. [6] [7]

This was in opposition to the EPA's draft risk assessment (which classified ETS as a Class A carcinogen). [8] and every other scientist on this list was a long-term tobacco industry scientist. Todhunter was available also to make comments to the press critical of the EPA. [9]


World Health Organisation (WHO): His curriculum vitae (from tobacco industry files) [10] shows that he has also served as:
Expert Advisor, Wor1d Health Organization, Europe Regional Planning Consultation on Risk Management (1984)

American Council on Science and Health (ACSH): He is involved in this chemical lobbying organisation run by Elizabeth Whelan.[11]

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