A Critical Opinion From Environmental Science Leaders

In a new Proceedings of the National Academy of Sciences (PNAS) opinion paper, former Environmental Protection Agency (EPA) and Office of Research and Development (ORD) scientists Scott Glaberman, H. Christopher Frey, and Tamara Tal issue a stark warning: proposals to eliminate ORD could have irreversible consequences for the nation’s environmental health, public safety, and scientific leadership.

The authors outline how losing ORD would dismantle the scientific infrastructure behind decades of environmental progress—and critically impair the country’s ability to respond to chemical, biological, radiological, nuclear, and explosive (CBRNE) threats.

While a court has temporarily paused the EPA’s reorganization, ORD staff remain in limbo. The stakes, as detailed by the authors, extend far beyond the agency—affecting everything from clean water and air to national emergency response.

The Scientific Engine Behind EPA’s Mission

ORD serves as the scientific foundation of the EPA, linking research, innovation, and regulatory decision-making. It enables the agency to meet statutory mandates under laws like the Clean Water Act, Clean Air Act, and Safe Drinking Water Act with sound, evidence-based policies.

Its research spans chemical detection, exposure modeling, risk assessment, and remediation—functions that cannot simply be outsourced to EPA program offices already overburdened by regulatory workloads.

Science in Crisis Response: ORD’s Homeland Security Role

One of ORD’s lesser-known but critical functions is its Homeland Security Research Program, which addresses scientific gaps in national disaster preparedness and response. This includes preparedness for CBRNE hazards—chemical spills, radiological events, biological contamination, and even explosive incidents.

ORD’s scientific expertise has supported the federal response to major crises such as the 2001 anthrax attacks, the 9/11 World Trade Center collapse, Hurricane Katrina, the Flint water crisis, and the 2023 East Palestine, Ohio, train derailment. In each case, ORD provided real-time contaminant monitoring, exposure modeling, risk assessments, and technical guidance.

The office plays a unique role in bridging environmental science with national security. Eliminating ORD would severely degrade the nation’s ability to prepare for and respond to large-scale chemical or radiological events—an unacceptable vulnerability in an era of climate-driven disasters and growing global instability.

Landmark Public Health Protections: From PFAS to GenX

ORD’s legacy includes leading-edge work on per- and polyfluoroalkyl substances (PFAS), which have been linked to cancer, endocrine disruption, and immune effects. ORD scientists were the first to detect the presence of hexafluoropropylene oxide dimer acid (commonly called GenX)—a little-known PFAS replacement—in the Cape Fear River Basin, which supplies drinking water to over 1.5 million North Carolinians.

Using advanced non-targeted chemical analysis and rapid toxicological testing, ORD linked GenX exposure to developmental harm in animals and supported public health actions that stopped further contamination. This case demonstrates ORD’s unmatched ability to connect chemical detection, health risk assessment, and emergency response.

Advancing Predictive Toxicology and Risk Science

ORD revolutionized toxicology with frameworks like Adverse Outcome Pathways (AOPs), which link molecular interactions to large-scale health outcomes such as cancer or reproductive dysfunction. These tools enable predictive, systems-based science across human health and ecosystems—moving toxicology from observational science into actionable forecasting.

ORD also advanced risk-based decision-making by integrating toxicity with real-world exposure data. Tools like the Integrated Risk Information System (IRIS) and the Exposure Factors Handbook are now foundational to public health risk assessments nationwide.

Supporting Public Health and National Interest

ORD’s work is not theoretical—it saves lives and prevents disease. Fine particulate matter (PM2.5), a leading cause of heart and lung disease, contributes to millions of deaths annually. ORD’s research linked PM2.5 to cellular inflammation and cardiovascular harm, ultimately guiding the EPA’s 2024 decision to tighten national air quality standards. That single change is projected to prevent 4,500 premature deaths each year and yield up to $46 billion in annual public health savings.

These efforts are critical to the U.S. national interest. Pollution does not respect political lines or geographic borders. It affects all communities—rural, urban, rich, and poor—and its mitigation demands sustained, independent science. ORD also supports the broader economy by reducing regulatory uncertainty for industry, especially in the face of evolving international chemical safety standards.

Innovation and Industry: A Collaborative Model

ORD’s leadership in New Approach Methodologies (NAMs) has transformed chemical testing by reducing reliance on animal models and accelerating safety evaluations. It supports innovation by validating regulatory-accepted methods and working with companies to ensure compliance and avoid costly missteps.

Its infrastructure—including the ECOTOX Knowledgebase and CompTox Dashboard—provides essential tools for thousands of scientists, regulators, and companies worldwide. These platforms are irreplaceable. Without them, industry would face slower approvals, higher costs, and global noncompliance risks.

The Global Stakes of Dismantling ORD

ORD has long been a global leader in chemical safety science. Eliminating it would signal retreat at a time when other countries are stepping up. The European Union recently committed €400 million to next-generation chemical regulation. Without ORD, the U.S. risks losing regulatory influence, innovation momentum, and public trust—both at home and abroad.

Conclusion: What’s at Risk?

The EPA’s Office of Research and Development is more than a scientific institution—it is a national asset that underpins health, security, innovation, and preparedness. Its elimination would fracture the EPA’s ability to respond to public health emergencies, protect vulnerable populations, and support domestic industry in a competitive global market.

The authors of the PNAS opinion piece are clear: dismantling ORD would be a profound mistake. It would endanger the public, undermine environmental justice, and compromise the United States’ scientific and strategic leadership in facing 21st-century threats—both seen and unseen.

Glaberman, S., Frey, H.C., & Tal, T. Dismantling EPA’s research office jeopardizes environmental safety, public health, and US competitiveness. Proceedings of the National Academy of Sciences. 11 June 2025.