EPA Administrator Scott Pruitt just released new proposed regulations that he claims will ‘strengthen science’ and address the ‘replication crisis.’ But let’s be very clear, these regulations will only serve to undermine scientific evidence and contribute to the real crisis here—unraveling public health protection in the U.S.
The rulemaking is based on prior proposed legislation in Congress oxymoronically named “The Honest Act”, but there was nothing honest about it—a more fitting name would be the “Dishonest Honest Act.” The legislation attacked what it called “secret science” and proposed bringing more transparency to the science forming the basis for EPA regulations. But what does Pruitt really mean when he says research should be more “transparent”? The rule proposes a requirement to share any underlying scientific data used in the development of regulations. In essence, this can eliminate studies the industry doesn’t like because the underlying data are not publicly available.
You may ask yourself, well why not just share the data? Data sharing and access is indeed an important aspect of the scientific process. NIH, other agencies, and scientific journals all have data sharing policies to ensure that data is open and accessible for scientific purposes. Additionally, scientists publish their methods, including how they obtained and analyzed their data as part of the transparent scientific process. However, research related to health involves people. People participate in our studies because they want to advance science and with the understanding that their information will be kept confidential. Would you be part of a study if all of your private information were shared with the government, or the industry who is opposing limits on pollution? What about your home address? Health studies routinely collect data that involves private information that should be protected, and not made publicly available.
Then, you may say, why not just redact the data to remove any personal identifying information? Sounds easy enough—but it isn’t. Redacting information about participant’s home addresses, diseases, household income, and other identifying information is cumbersome and costly. Studies involving rare diseases can mean that no matter how much information is redacted, individual participants can still be identified. This places a heavy burden on scientists to protect the personal information of their study participants in order for their data to be used to inform environmental regulations, something that they won’t receive funding or incentives to do. But the chemical companies will be incentivized to redact and provide their data—the same chemical companies that don’t have studies that demonstrate that exposure levels are safe and that their chemicals don’t pose health risks.
But wait… there’s more. Like an industry Christmas list, this proposed rulemaking is full of wish list items reflecting how industry wants science to be conducted. For example, the regulation promotes the use of ‘Good Laboratory Practices,’ something scientists have said inappropriately weights these studies which often use old scientific methods over academic studies. They even propose to legislate what science EPA should use in determining the relationship between exposure and health effects. In short, these are all efforts to give industry what they have been after for decades—to create doubt in the science and use it as an excuse to ignore studies that don’t give the “right” answer, all in the name of “transparency.” Last we checked, the mission of the EPA was to “protect human health and the environment,” but these proposed regulations will almost certainly have the opposite effect.
Juleen Lam, MH, MHS, PhD, co-wrote this post. She is an Associate Research Scientist on the Science & Policy Team at PRHE.