Deconstructing Regulatory Science
Originally published on The Regulatory Review. Reprinted with permission.
The U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt recently opened another front in his battle to redirect the agency away from its mission to protect human health and the environment. This time, he cobbled together a proposed rule that would drastically change how science is considered during the regulatory process.
Opposition soon mobilized. In addition to the traditional forces of public interest groups and other private-sector watchdogs, the editors of the most prominent scientific journals in the country raised the alarm and nearly 1,000 scientists signed a letter opposing the proposal.
This essay offers a contextual explanation of the reasons why scientists, who are typically loathe to enter the regulatory fray, are so alarmed.
In normal times, when agencies must evaluate the scientific evidence that informs a significant policy decision about health or environmental hazards, they typically take four sequential steps:
- First, they convene a group of respected scientists from within and sometimes from outside the agency that includes representatives of the disciplines needed to make the determination, such as neurologists, statisticians, pediatricians, and hydrogeologists.
- Second, the scientists gather all the available scientific research and review it carefully, making informed judgments about which studies are more or less convincing.
- Third, in a synthesis stage known as
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