14 November 2019

Strengthening Transparency in Regulatory Science”

The New York Times reports that the Environmental Protection Agency (“EPA) is mooting plans to regulate which scientific sources it relies on for policy-making. The new document is a proposal which updates the proposed rule in 2018 and appears to require significant disclosure of data for the sources to be accepted.

A new draft of the Environmental Protection Agency proposal, titled Strengthening Transparency in Regulatory Science, would require that scientists disclose all of their raw data, including confidential medical records, before the agency could consider an academic study’s conclusions. E.P.A. officials called the plan a step toward transparency and said the disclosure of raw data would allow conclusions to be verified independently.

This updated proposal appears to broaden the approach in two key ways: (1) by applying the requirement to all data models, not just dose-response studies, and (2) by applying the requirement retroactively to reassess the scientific basis for its policies.

It is worth noting that the New York Times has characterised this proposal as part of the Trump administration’s attempts to weaken the scientific underpinnings of policymaking”, citing the following conduct:

Senior administration officials have tried to water down the testimony of government scientists, publicly chastised scientists who have dissented from President Trump’s positions and blocked government researchers from traveling to conferences to present their work.

But I think that there is good ground for thinking that this proposal is not quite as sinister as that, although it may have many consequences for environmental regulation. It seems, instead, that there is a fundamental misalignment between the current EPA administration’s view of science and how the scientific community views its own endeavours. Part of this is the fact that these two communities operate on very different assumptions about what constitutes reliable knowledge.[^ Vaguely related to Luhmann’s work on systems theory, especially below.]

This issue operates on at least two levels. First, on the level of the substance of the studies, the EPA appears to assume that it has the responsibility of re-assessing the scientific conclusions because it is in charge of making policy. It doesn’t appear to understand that that’s not how science works — although reproducibility and repeatability are traits of scientific research, these are not the only values at work, and a scientific study can have an impact even if the results cannot be reproduced.

Second, and more fundamentally, there is a lack of trust between the regulator and the scientific community. Intra-community trust is built up by shared professional norms and censures for those who go outside of them. There is also an on-going work of critique and progress by developing on the work of others. But in these proposals, the EPA clearly shows that it does not trust the results, but also does not trust the processes by which the results are arrived at.

Standing on the shoulders of giants is hard when you’re not so sure that the thing underneath you is a giant, and if you suspect that it’s a volcano just about to erupt.

These proposals show that there is a disjunction between how the EPA perceives science and how the scientific community does (or at least thinks it does) science. But this lack of trust actually shows a more problematic relationship — the EPA appears to be projecting its political assumptions onto the scientific community, seeing it” through political lenses, and interpreting it along those lines. This lack of trust is distinctly contrary to the spirit of the science research community, but fits right in to the political landscape, where data and facts are so quickly twisted for whatever end.

But can you really blame the EPA? In a sense, science has been politicised for quite some time now. The fact that science has become so heavily relied upon in regulation and in the law (even in the courts, when debating certain rights) means that the scientific outcomes have a higher stake. And that also means that it is easier to begin to suspect that the scientific community will not arrive at objective conclusions. Whose fault is it? That’s not really the point of the analysis. But if we try to grasp what is going on here, I think we can see just another manifestation of the fact that both politics and science, as systems”, have become too intertwined — there is still sufficient difference for friction, but much of this friction arises because there isn’t enough difference between them.

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