Rejected
Thank you very much for reviewing my manuscript entitled “Plausible
In, Plausible Out: A Bootstrap Methodology to Characterize the Uncertainty
Associated With Dose-Response Modeling”.
I am disappointed in the result, of course. However, as it met the same fate as every
other paper on model uncertainty that I have sent to the various and sundry
editors that the Journal has had over the last 25 years, I am not terribly
surprised.
I think I will not attempt to rewrite the paper to make it more
acceptable. The paper says what I want
it to say and I don’t think any of the major suggestions made in the review will make
it any better. A similar example to that
discussed in the manuscript is also in the FDA (2016) assessment on arsenic in
rice released two weeks ago (see section 9.4), and I suppose my purposes will
be better served by working the rest of the text into my other writing projects. Nonetheless, for the benefit of my colleagues who are
interested in model uncertainty in general and this paper in particular, I
would like to address some of the comments made in the course of the review.
A Methodology Paper
The paper I submitted is a discussion of two methodological developments
used in USFDA assessments for arsenic in apple juice (Carrington et al, 2013)
and rice (USFDA, 2016). The first method
involves the use of a parametric bootstrap simulation to propagate the
uncertainty associated with dose estimation into the characterization of the
dose-response relationship. Putting
error bars on the doses is a novel technique and as just about everyone I know
thinks it is a pretty good idea, this was the impetus for writing the paper in
the first place. Although the reviewers
didn’t seem to think this technique was remarkable, at least they didn’t object. I guess it really is a pretty obvious thing
to do once you’ve thought of it. The
second reviewer did suggest that additional details be provided about the input
distributions for the dose estimates. I decided
not to do that when I wrote the paper because I thought getting into specifics
would be a distraction from the more general idea of allowing dosimetric uncertainties
to be represented in a dose-response analysis. If I get around to reworking the analysis for
some other purpose, I will heed those suggestions to the extent that I can; many of the issues raised by the second reviewer resulted from the necessity of working with published summary data rather than observations from individual subjects. However, for a methodological presentation where no importance is attached to the actual results at all, I don't think any of that matters.
Against the wishes of potential FDA coauthors, I also chose
to include a discussion of model uncertainty.
Since this was and is the hot button political topic for any risk
assessment involving arsenic and any other chemical hazard worthy of attention I
thought it would be a serious omission to not include it, especially since
there may often be an interaction between dosimetry and empirical weighting of
alternative models. As near as I can
tell, the reviewers haven’t raised any serious objections to anything I said
about model uncertainty, but it is very clear that they really don’t like the
way I said it. This may be partly due to the fact that the reviewers didn't take the discussion in the methodological context that was intended, but since this seems to be
the reaction I always get when I try to talk about model uncertainty, I think there is more to it than that. I think I understand the nature of this editorial issue far better than I used to, so I will
take this opportunity to explain.
Unfinished Science
Model uncertainty is subjective. Some people have it and others don’t. I think the two basic causative factors are
as follows:
- The model has to be thought of as a theory. Even if it is only approximately correct, the mathematical model has to convey some truth that is not evident from isolated observations.
- There has to be more than one model-theory. If only one model is under consideration, then there is no uncertainty.
Taken together, these two criteria basically mean that if
you are afflicted with model uncertainty then you are thinking like a scientist. But here’s the thing; if you have it then you
can’t really talk or write about model uncertainty in the objective third
person writing style generally preferred by governments and journal editors. You can describe a model uncertainty as a psychological
phenomenon as I just have, but that is pretty much the end of the third person road. If you think it is just me who can’t write
properly, go back and read the most widely cited paper on model uncertainty ever
written (Hill, 1966): It is written almost entirely in the first or second person. For example, the problem the paper sets out
to solve is stated as follows:
Our observations reveal an association between two variables, perfectly clear-cut and beyond what we would care to attribute to the play of chance. What aspects of that association should we especially consider before deciding that the most likely interpretation of it is causation?
Part of the problem is that scientists don’t write their
papers in the same manner as they converse in private. When papers are written, it is often because
model uncertainties have been resolved and what were once just theories are
reported to be objective realities. But risk analysts can’t do that. There are many model uncertainties that have not
been resolved and they may never be, which leaves us with probability trees and
subjective weight-of-the-evidence evaluations.
My Problem
The apple juice and rice risk assessments both used probability
trees to depoliticize arguments over which dose-response model “should” be used
to characterize the causal relationship between inorganic arsenic and cancer. I am happy to report that this strategy
worked as I hoped that it would. The two
assessments employed somewhat different strategies for assigning probabilities to
alternative models. Because I think it
is more consistent with how scientists actually think, I prefer the strategy
used in the rice assessment that largely relies on expert opinion.
My only reservation is that the probabilities used for the
rice assessment relied only on my opinion.
As an expert, assigning probabilities to theories was implicitly part
my job description at the FDA, and I’m not complaining about having to do what
I was paid to do. I have a PhD in Pharmacology and long
experience in modeling dose-response relationships, so I don’t feel unqualified. However,
my primary area of expertise is neurotoxicology rather than cancer biology, and
I am far more familiar with the literature on lead and methylmercury than
arsenic. So, it would have been nice to
have other experts involved, especially if the stakes are raised from just setting
guidance values for apple juice and infant cereal that have relatively little
economic impact to suggesting that consumers modify their rice intake. But in order move from the subjective “I” to
the intersubjective “We”, I think that those of us who are afflicted with model
uncertainty need to be permitted to write in the same way as we converse
among ourselves, and we can’t do that if we are forced to pretend to
objectivity that we really don’t have.
References
Carrington CD (unpublished).
Plausible
In, Plausible Out: A Bootstrap Methodology to Characterize the Uncertainty
Associated With Dose-Response Modeling.
Carrington CD, Murray C, and Tao, S. (2013). A
Quantitative Assessment of Inorganic Arsenic in Apple Juice.
Hill, Sir Arthur Bradford (1965). The
Environment and Disease: Association or Causation? Proc
Royal Soc Med 58:295-300.
U.S. Food and Drug Administration (2016). Arsenic
in Rice and Rice Products Risk Assessment.
Official Post Soundtrack
Green Day (1997).
Reject. In: Nimrod, Track 14.
Post Notes
Thesis Post #64. Even though I will probably group it in the arsenic series, this post is really about academic politics.
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