Public policies–particularly important regulatory decisions–often turn on scientific issues. Unfortunately, according to Dr. A. Alan Moghissi of the Institute for Regulatory Science, most regulations are based on poor science.
Speaking at the Dixy Lee Ray Conference held in Washington at the end of August, Moghissi briefly discussed what constitutes sound science and how to distinguish good science from bad. Before joining the Institute for Regulatory Science as president, Moghissi was a principal advisor on radiation and hazardous materials to the U.S. Environmental Protection Agency (EPA). He is also chairman of the American Association of Engineering Societies.
The many scientists and engineers in attendance for Moghissi’s presentation may have viewed it as a review of basic principles. But his comments deserve wider attention, especially from policymakers and the public at large, who are all too often influenced by misused and abused science.
Junk Science Vs. Sound
Moghissi identified four classes of science, the first two constituting “junk science” rather than sound.
First, Moghissi explained, there is personal opinion–which is usually what the media prints despite the fact that it is useless for the purposes of sound policy-making. Moghissi expressed his dismay that this form of “science” all too often guides public policy debates and has a profound impact on what topics even reach the political agenda.
Second, there’s what Moghissi called “gray literature.” This includes information on scientific issues that advocacy groups and others pull together. It never undergoes the scrutiny of the scientific process, and is little more than personal opinion with organizational trappings. This form of junk science is becoming increasingly prominent in policy debates, Moghissi warned, particularly on environmental and regulatory topics, where non-government organizations (NGOs) wield substantial influence.
Moghissi’s final two classes constitute sound science. One class includes studies that undergo peer review: a scientific study is not considered valid until a jury of the scientist’s peers say it’s valid. One member of the audience observed, and Moghissi agreed, that even peer-reviewed science does not always reach valid conclusions. Even with peer review, papers arrive at opposite conclusions, and at times, peer review is not as rigorous as it should be.
Scientific findings gain their greatest strength after many studies and much debate lead the scientific community to a general consensus on an issue, which comprises the fourth class. When lawmakers act in areas of scientific consensus, they have the best chance that their policies will be based on sound science, says Moghissi.
Other Types of Scientific Information
In addition to the four categories of science, Moghissi noted, there are other types of scientific information. Scientific laws, for example–such as the laws of gravity–apply everywhere and constitute the best scientific information. The application of those laws to observed phenomena constitutes another form of scientific information, not quite as powerful as laws universally deemed valid, but close.
Scientific information is only rarely clearcut; in many cases, Moghissi notes, it is problematic and controversial. This can happen, for example, when policymakers or advocates extrapolate from one set of data to something far beyond the case at hand. A clear example, noted Moghissi, is when the observed effects of extremely high-dose exposures to a chemical in a rodent are extrapolated to the potential impacts of very low-dose exposures in humans.
Who’s Issuing Junk Science?
While Moghissi himself rarely pointed an accusing finger at junk science purveyors, his comments on gray literature left many in his audience discussing the work of such groups as the Environmental Working Group (EWG) and Natural Resources Defense Council (NRDC).
Both groups have published many “studies” about the threat to human health posted by pesticides and chemicals. These reports cite a few scientific studies, sometimes even peer-reviewed ones, that might suggest a weak association (not a cause-and-effect link) between some chemical and an illness. The report inevitably will conclude that “millions of Americans are at risk,” without reporting that other studies contradict the findings of those they cited, or that there’s no scientific consensus on the issue.
Both the EWG and NRDC have used such studies to lobby for the reauthorization of the Federal Safe Drinking Water Act, a law under which EPA has imposed nearly 100 distinct regulations on drinking water systems nationwide. Many of regulations are costly to comply with and produce little benefit to human health. Such sham studies have also encouraged EPA to ban certain pesticides that are highly valuable in protecting our food supply and controlling disease-carrying household pests.
Even the popular publication Consumer Reports publishes such junk science to lobby for a wide range of new government regulations, scaring the public into supporting a radical agenda. In one recent issue the magazine reported its own “study” of the risks associated with PVC plastics, used for such things as baby bottles. Consumer Reports used this unpublished, non-peer-reviewed “study” to claim that baby bottles release chemicals that could poison children. Yet PVC baby bottles have been used for 40 years without any documented harm to children, and scientists have been unable to replicate Consumer Reports’ findings.
After Consumer Reports published its article, a panel of 16 scientists, led by former Surgeon General C. Everett Koop, analyzed 122 of the top scientific studies on the topic. The panel concluded that PVC plastics are safe. Nonetheless, Greenpeace is using the momentum generated by the Consumer Reports study and other junk science to bolster a campaign to ban these products. Efforts are underway worldwide to eliminate the use of these plastics for toys and even for vital medical devices such as blood bags. (For more information on this controversy, see “Panel provides clean bill of health for vinyl toys and medical devices,” Environment News, August 1999.)
There can be little doubt that the misuse and abuse of science can have profound public policy impacts. Moghissi’s comments give lawmakers and the rest of us some good principles to follow when considering these issues.
Angela Logomasini is director of risk and environmental policy at the Competitive Enterprise Institute. She can be reached by email at [email protected].
