The committee furor and the Certainty Principle

Abstract

Providing governments with advice on difficult problems, especially those involving environmental quality, is an increasingly serious responsibility for the scientific community. In fulfilling it, we need to make sure that our input is thoughtful and technically capable, and that it reflects judgments uninflected by political or ideological conviction. It is equally important for the government to seek out the most knowledgeable scientific and technical sources for the advice it needs, and to ensure a balance of views from the advisers it chooses. Here in the US, recent actions by the administration regarding federal advisory committees are raising questions, both for government and for scientists. Objections have been raised over the non-renewal of committees that have been important to the nation's health – for example, the National Human Research Protections Advisory Committee, established in 2000 in response to deficiencies in the protection processes for human subjects, and the Advisory Committee on Genetic Testing, appointed by the Secretary of Health and Human Services. Continuity is important in both these areas, and it is hard to imagine that these vacancies can be allowed to remain. The advisory committee fuss is not only about cancellation. In an area of great importance to environmental scientists, a Centers for Disease Control and Prevention advisory committee for the National Center for Environmental Health (NCEH) was subject to almost wholesale replacement – involving 15 out of 18 members. Whenever that sort of things happens, suspicions flourish. Thus it is no surprise that some lively politics are being played out here. Indeed, an editorial by David Michaels and colleagues in the October 2002 issue of Science (Vol 298, p 703) has produced a flood of letters from persons whose service on other scientific advisory committees has been denied because they failed to pass various ideological litmus tests. The concern is understandable, and much is being made of the character and past record of certain individuals among the new members – a natural enough reaction, given the unexpectedly abrupt character of the dismissals. But the scientific community would be mistaken to single out for criticism the past positions and associations of particular individuals. Advisory committees work best when various views are present; balance is important, because it facilitates the kind of understanding that results from debate and compromise. That said, it makes sense to look at the entire roster and reach a judgment about the fairness of its composition – not person by person, but in terms of balance. Some new members of the NCEH committee appear to share a general philosophy of regulation that may be called the Certainty Principle. Whether the topic is beryllium toxicity, climate change, or the carcinogencity of asbestos, the argument runs like this: if there is still some uncertainty, we should withhold regulatory action. That is a recipe for gridlock, because governments have to make decisions about risk even when the data aren't as good as we would like. To be fair, though, the Certainty Principle probably originated as a reaction to the widespread use by the consumer and environmental movements of the Precautionary Principle, an all-purpose argument for wider safety margins. Neither is really a principle. Each is a formula, resting on assumptions about how much protection from risk societies owe their members. Scientists ought to want the NCEH committee in action, along with those FDA advisory committees, and the others. The nation needs them. For every new member who is a habitual defender of the Certainty Principle, there should be an equally informed and persuasive advocate for the Precautionary Principle. After all, convictions about risk and how we should manage it belong in the mix, but only in moderate doses. The majority of members should be scientists who are unswervingly devoted to neither, “principle” but annoyingly persistent about getting more data and doing more analysis. Prof. Donald Kennedy, Editor-in-Chief