Scientists from the public and private sector as well as academia could all have something to rally behind under the current Administration and Congress: a stronger appreciation for using good science to help drive regulatory decision-making.
Congress has already begun to take action. This morning, Dr. Nancy Beck, Ph.D., provided testimony to a Senate Subcommittee about federal agencies’ use of science in the rulemaking process, particularly as it relates to chemical risk assessment. Dr. Beck has also been invited to share some examples of where scientific information in the rulemaking process may have fallen short, and to outline proposals that agencies could use to improve transparency and accountability.
With nearly 20 years of applied public health experience, including serving in the U.S. Office of Management and Budget as a toxicologist and science policy analyst, Dr. Beck is an indispensable resource who knows how to work with others to help bring greater reliability and accountability, transparency, and balance to the regulatory process.
Accountability, reliability and transparency
Science is fast-moving and ever changing. Certain practices and procedures can help ensure risk assessments being relied upon, especially in rulemaking by the federal government, are employing the best available science and the weight of the scientific evidence approaches. Ensuring the greatest weight is given to the highest-quality and most relevant studies results in accountability.
Science should also be reproducible and transparent to increase confidence across the board in scientific information. Making available the underlying data used in regulatory decisions increases transparency and allows for a higher level of reproducibility, especially regarding statistical analysis. This can be achieved while protecting proprietary information, personal information, and confidential business information through smart use of data transfer agreements and other tools consistent with the law regarding trade secrets.
People often don’t realize that the overwhelming majority of science developed to ensure the safety of chemicals in commerce is conducted by the private sector — and that will continue through both Democratic and Republican Administrations.
Unfortunately, we have often seen situations where Agency peer reviewers say “any industry-funded science should be dismissed,” or they refuse to include industry representatives on peer review panels. This discounts an important voice at the table — and without this science, agencies exclude a large body of research that can help paint a clear picture of a product’s safety.
Industry is far more than just “the regulated community”; we are developing some of the highest-quality science there is. That’s why we believe it’s important to work together with the government to find ways to ensure that scientific protocols are validated, employed, and embraced by private, independent entities (like a peer review panel), that accept the data and the outcome of a high-quality study. The same standards should be applied and adopted by all, be it industry, academia, or a federal agency. This is especially true when it comes to chemical risk assessment.
We believe that we have an exciting opportunity in this Administration, under EPA’s new leadership, for the Agency to have comprehensive reform in the way it performs chemical risk assessments, developing a gold standard of scientific methodologies in chemical assessment and safety. Updating EPA’s risk assessment practices will result in public trust in the Agency’s determinations of safety.
If trusted, these determinations will be embraced by other agencies, state regulators, and consumers.
Why it matters
Our society needs accurate safety assessments and a regulatory environment in which the chemical industry can be at the forefront of new products that help meet sustainability needs and provide the performance that people are looking for in everyday products.
The ‘gold standard’ translates to standardized protocols, giving companies the certainty that, by following the protocols, they will obtain the necessary regulatory approvals and access to the marketplace.
If we all play by the rules prescribed by agencies, and invest in good, quality science, we should be able to get the regulatory green light to provide consumers access to new, innovative products.
That’s why ACC and our members are urging federal agencies to update and improve their science and to call on all scientists to work together to ensure the public can benefit from a more accountable, reliable, balanced and transparent chemical regulatory process.