Scientist Civic Engagement and the US EPA’s “Strengthening Transparency in Regulatory Science” Rule

Abstract

BACKGROUND AND AIM: For decades, vested interests, including tobacco and oil companies, have sought access to data used by observational epidemiologists, even when involving private health data. This has included attacks on environmental epidemiology, calling it “Secret Science”, in tandem with efforts to push legislation through the US Congress. History has shown that vested industries have abused such data access, and the legislation failed. More recently, the Trump Administration attempted a regulatory “end around” of Congress, via the so-called “Strengthening Transparency in Regulatory Science” rule. METHODS: The North American Chapter (NAC) Policy Committee participated in preparing and presenting written and oral testimony to the US EPA and Office of Management and Budget (OMB) during hearings and requested meetings. These submissions are online at our web page: https://isee-northamerica.github.io/isee-nac/policy.html. These records documented the many problems with the proposed regulation, including: increased potential for compromise of medical record confidentiality; a loss of intellectual property; imposition of a government unfunded mandate; likely abuse of the research data to inappropriately undermine science credibility; and, damage to future scientific research recruitment efforts. RESULTS:The ISEE NAC Policy Committee recognized the above noted dangers to scientific research, and especially environmental epidemiology and took action, via civic engagement with the government, to put in place a record of those problems for future consideration by the courts in likely later legal efforts to overturn the ill-conceived regulation. At the same time, these government meetings, along with those by other scientific societies, slowed the progress of this potential regulation. In addition, scientists worked with lawyers to prepare legal challenges to the regulation. Ultimately, these efforts succeeded in delaying the regulation long enough for it to be successfully revoked by the incoming Biden Administration. CONCLUSIONS:The ISEE NAC Policy Committee provides a means for our member scientists to successfully influence government decision-making through civic engagement. KEYWORDS: Policy, Research translation, Science communication, Transparency, Civic engagement