others have rejected the research only on scientific grounds, criticizing methodological inconsistencies. those in favor of using the data argue that if it has practical value to save lives, it would be equally unethical not to use it. arnold s. relman, editor of the new england journal of medicine from 1977 until 1991, refused to allow the journal to publish any article that cited the nazi experiments. "i don't want to have to use the nazi data, but there is no other and will be no other in an ethical world ... not to use it would be equally bad. i'm trying to make something constructive out of it." dr john hayward, justifying citing the dachau freezing experiments in his research. the results of the dachau freezing experiments have been used in some late 20th century research into the treatment of hypothermia; at least 45 publications had referenced the experiments as of 1984, though the majority of publications in the field did not cite the research. those who have argued in favor of using the research include robert pozos from the university of minnesota and john hayward from the university of victoria. in a 1990 review of the dachau experiments, robert berger concludes that the study has "all the ingredients of a scientific fraud" and that the data "cannot advance science or save human lives." in 1989, the united states environmental protection agency (epa) considered using data from nazi research into the effects of phosgene gas, believing the data could help us soldiers stationed in the persian gulf at the time. they eventually decided against using it, on the grounds it would lead to criticism and similar data could be obtained from later studies on animals. writing for jewish law, baruch cohen concluded that the epa's "knee-jerk reaction" to reject the data's use was "typical, but unprofessional", arguing that it could have saved lives.