STS Community: Would Like to Hear What You Think About Proposed EPA Transparency Rule

The current major media stories quote people who say something like “transparency is generally good, but not here.” We all know that EPA does health studies but we also know they do much other regulating as well. Say climate, or biomass or …. So I would like to know, given that feedback, what if the EPA just used it for the non-health studies? Is there a way to review the health studies’ calculations without going to the level of personal data? The standard newspaper stories seem to be “good people hate this proposed rule, only bad people (“climate deniers,” industry) support it.” That is really not all that helpful in terms of a news story for us folks that are trying to understand the pros and cons.
Here’s one story from the Scientific American:

Smith said.. Many in the scientific community agree that increased access to data is essential for reproducibility and objective analysis,” he said. “Open access to scientific data fosters good policymaking. The American people have a right to understand how and why regulatory decisions are made.”

In a House office building last week, Smith feted a group of researchers from the National Association of Scholars who routinely attack climate science and who say in a new report that there is a “crisis” in science because too much of it cannot be reproduced. The authors of its new report, titled “The Irreproducibility Crisis of Modern Science,” say government agencies should establish review commissions to determine which existing regulations are based on reproducible research and to rescind those that are not, a process that could affect key provisions of the Clean Air Act, among other regulations.

For those of you who don’t follow science biz studies (the social science of observing the science biz), here’s a link to a piece by Andrea Saltelli on “Science’s credibility crisis” that gives some background of some of the issues across disciplines. This paper has many interesting links.

Ravetz emphasises the loss of this essential ethical element. In later works he notes that the new social and ethical conditions of science are reflected in a set of “emerging contradictions”. These concern the cognitive dissonance between the official image of science as enlightened, egalitarian, protective and virtuous, against the current realities of scientific dogmatism, elitism and corruption; of science serving corporate interests and practices; of science used as an ersatz religion.

Echoes of Ravetz’s analysis can be found in many recent works, such as on the commodification of science, or on the present problems with trust in expertise.

Ioannidis and co-authors are careful to stress the importance of a multidisciplinary approach, as both troubles and solutions may spill over from one discipline to the other. This would perhaps be a call to the arms for social scientists in general – and for those who study science itself – to tackle the crisis as a priority.

Here we clash with another of science’s contradictions: at this point in time, to study science as a scholar would mean to criticise its mainstream image and role. We do not see this happening any time soon. Because of the scars of “science wars” – whose spectre is periodically resuscitated – social scientists are wary of being seen as attacking science, or worse helping US President Donald Trump.

I think this would be a good time for social scientists who study science (the science and technology studies or STS community) to step up, dare to be labelled as denialist or Trump supporters and say “we resist the use of science as tool of partisan warfare”. Perhaps something along these lines “From our perspective, based on decades of study of the scientific processes and regulatory science in particular, we think regulatory science might be helped by open data in these situations.. but not these.. and would instead suggest …”.

9 thoughts on “STS Community: Would Like to Hear What You Think About Proposed EPA Transparency Rule”

  1. Check out:
    My husband is a biostatistician at Washington U medical school associated with hospital. does a lot of work with NIH etc. he thinks this proposal is nuts. Obviously it does not work for health issues.
    Probably would not work for many businesses either. Will Monsanto, DuPont research etc comply?
    This effort uses the value of transparency to cripple the use of science.
    If a reasonable and higher standard of transparency is applied, there would certainly need to be a period of adjustment. Science is a cumulative effort.

  2. My $.02 is that Pruitt’s new rule is pure Orwellian doublespeak in which “transparency” is used to exclude findings that the industries he represents don’t like — and, in the process, would also expand the role of industry science in decision-making and make it much more opaque.

    And as justification, he invokes the “reproducibility crisis,” which is largely restricted to social science and certain fields of biomedical research. Though it’s important to confront — and is part of the reason I take social science and biomedical stuff with several grains of salt — critiquing the “reproducibility crisis” has become a fashion unto itself, and it’s often done by people who elide the differences between research areas.

    Pruitt’s use of it is cynical and intellectually dishonest, and the effect will be to make it easier for companies to harm people — especially poor people, children, and the vulnerable — without being accountable for it.

    Also good links:

    • For what it’s worth, the US Fish & Wildlife Service report, “Defining and Implementing Best Available Science for Fisheries and Environmental Science, Policy, and Management,” Sept. 2006, has this definition:

      Science and the Scientific Process
      To achieve high-quality science, scientists
      conduct their studies using what is known
      as the scientific process, which typically
      includes the following elements:

      • A clear statement of objectives;
      • A conceptual model, which is a framework
      for characterizing systems, making
      predictions, and testing hypotheses;
      • A good experimental design and a standardized
      method for collecting data;
      • Statistical rigor and sound logic for analysis
      and interpretation;
      • Clear documentation of methods,
      results, and conclusions; and
      • Peer review.

  3. I don’t know, isn’t the identity of participants already coded in the study? Seems like those could be stripped out.

    Seems to me as a scientist and a member of the public, that everyone’s research should be on a level playing field with regard to transparency and data quality requirements, including Monsanto. I might even design a peer review process for very significant questions in which papers would be peer reviewed by the same panel of other scientists with a variety of perspectives. I would also have a panel of diverse interests to consider exceptions.

    If we believe that transparency and I would add QA/QC for policy relevant papers is a goal, then the question is when and where to start phasing it in, and whether to use carrots (extra weight given to the study) or sticks (can’t use unless it has it).

    I advocated it for open access to data for any policy-relevant research) here :

  4. Open access to data is good. And we are moving more toward that. But underlying data is different than exposure of names of individuals involved and so called trade secrets.
    Health studies are now required to be encrypted to protect privacy. But many useful studies from recent past do not and may not meet the current bottom line transparency requirements. It is my understanding that the EPA would not even acknowledge references to such studies as permissible.
    Pruitt was on TV tonight trying to deflect responsibility for all his ethical problems. But I also heard a snippet in which he said EPA would protect all revealed personal and trademark data etc. obviously more to learn on this, but who would trust Pruit’s EPA with any private information?

  5. I think there is a big difference between having a goal of transparency and prohibiting the use of any undisclosed information source. There is no reason that a decision maker couldn’t consider this as one of many factors in determining “best” science. This is a solution without a problem.

    I also see this as primarily an effort to shift the burden of impacts towards the public and away from those who cause them. I’d rather see the debate be about that balance, with the use of science being only a part of that discussion.

    • Some of you may recall the Threatened and Endangered Species Recovery Act of 2005, which passed the House but did not advance from there. The bill would have included a definition of “best available scientific data” for use under the ESA: best available scientific data “means scientific data, regardless of source, that are available to the Secretary at the time of a decision or action for which such data are required by this Act and that the Secretary determines are the most accurate, reliable, and relevant for use in that decision or action.”

      Marten Law has a detailed history of the proposed bill. It notes that:

      “Environmentalists argue that this new definition politicizes science by allowing “a political appointee, the Secretary of Interior, rather than scientists, to decide what constitutes the best science[.]” According to some in the environmental community, rather than leave the definition up to the scientific community as the ESA does, H.R. 3824 would “allow greater political manipulation of scientific decisions.” Center for Biological Diversity, Stop H.R. 3824. At least one science and technology commentator fears that such politicization will cause “competent scientists [to] avoid public service, degrading the quality of advice to policy makers and the public[.]” John Horgan, Political Science, N.Y. Times, Dec. 18, 2005.”

  6. It is interesting to me that when I worked in regulations, environmental groups who were promoting “best available” science for FS activities (which tends to slow down projects that are considered to be bad for the environment), were also against efforts to clarify good science in the regulatory sphere (because regulations are good for the environment, and considerations like making science higher quality may slow them down). These attitudes make total sense in terms of the agendas of environmental organizations, but make it difficult to be the federal government (which does both kinds of decisions) and to have one set of rules for using science in policy.

    It seems to me that this is all about scientists and scientific organizations maintaining their privilege as authorities to both a) police themselves and b) tell policy makers what to do. That’s what makes folks like the AAAS so concerned about this.

    Regulatory science is apparently not always clearcut anyway, without the transparency twist. check out this piece.. .

  7. This particular administration wants to DEregulate, and environmental organizations want to slow them down by holding them to some actual science. These organizations are consistent in advocating for whatever best protects the public. That would not be “difficult” for the federal government to do.


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