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House bill targets science
Guest post by Kirk Willmarth.
The House of Representatives recently passed H.R. 1422, the EPA Science Advisory Board Reform Act. This bill continues to generate substantial controversy around several of its proposed changes, including:
A clause that stipulates that: “Prior to requesting scientific advice from the Board, the Administrator shall accept, consider, and address public comments on questions to be asked of the Board. The Board, member committees, and investigative panels shall accept, consider, and address public comments on such questions and shall not accept a question that unduly narrows the scope of an advisory activity.”
- The clause introduces public involvement prior to asking questions to the advisory board, and also compels the board to respond to these comments.
Another clause that states: “Board members may not participate in advisory activities that directly or indirectly involve review or evaluation of their own work“.
- This clause seems to exclude scientists from advising in their own area of expertise.
An oft-discussed topic within Science & Society is the appropriate role of science for informing policy. Like scientific advice, public comment is an important part of the policy process. However it seems that the role of both is to provide one input to policy makers directly, who can then synthesize the information into appropriate policy. It seems that public comment and scientific advice should be treated as two inputs to the policy process.
By forcing the scientific advisory board to respond to public comments, H.R. 1422 confounds the separate roles that public opinion and scientific expertise play. An analogous situation comes from law: lawyers for both parties submit their case before a judge. Interested parties may also submit amici briefs to the judge as another input. This House regulation seems to be analogous to forcing attorneys to receive and respond to amici brief before submitting their own cases. The application seems improper and inefficient.
Regarding the second clause, this author believes that excluding scientists from providing advice about one’s own area of expertise is a mistake. I agree with the comment from the Union of Concerned Scientists: “a scientist with expertise on topics… likely will have done peer-reviewed studies on that topic. This makes the scientist’s evaluation more valuable, not less.” To require that scientific advisory board members be non-experts undermines the purpose of having these boards in the first place.
I support the role of proper science in informing policy makers and regulatory bodies. Parts of this measure raise very serious concerns about diminishing the quality and impact of science and scientific experts in advising EPA action.
Kirk Willmarth holds a BS in Biology from Duke University, an MS in Developmental Biology from Stanford University, and is a candidate for Duke’s MA in Bioethics & Science Policy.