SPSG #13: Ending the Game

This chapter outlines strategies for overcoming the difficulties noted in earlier chapters. First, adopting some common legal strategies for separating Matters of Fact from Matters of Law could do wonders. The creation of job positions for Science Judges whose sole responsibility is to disentangle science matters from policy matters could facilitate that. Second, while eliminating the science-policy shell game entirely is probably not possible, there is no reason why it should be condoned or institutionalized. Therefore, the EPA assessment guidelines for cancer and noncancer endpoints both need to be rewritten. As the face of the Safety Assessment Paradigm, the Reference Dose background document should be rewritten to make it clear that the product of the assessment is a regulatory policy rather than a statement of scientific fact. As for the cancer risk assessment guidelines, instead of enshrining the default option with the Point of Departure, the guidelines should use probability trees to make the default option going away entirely. Furthermore, there is no reason to the restrict the use of quantitative risk assessment to just cancer. However, solving that problem will create another problem: At least in public health, a legacy of the institutionalized use of the science-policy shell game has virtually eliminated risk management as a federal job position. So, doing a risk assessment is of very little use if no one in the federal government has the responsibility for managing issues. That can happen, but position descriptions will need to be rewritten. Finally, research should be funded to support science, instead of supporting technocratic shell games. In particular, the enterprise of environmental epidemiology needs to be redesigned. Statistical significance testing should be eliminated as the primary means of drawing conclusions from data, and studies should be designed to increase or reduce evidentiary weight accorded to causal theories instead. Perhaps most importantly, observational data needs to be shared. When it comes to analyzing data, regardless of what their source of funding is, investigators cannot be given complete deference in conveying what the data infer. As an academic recommendation, teaching Statistics and Probability as separate subjects would clear up more than a few nagging philosophical problems.  Finally, the facade of impersonal scientific objectivity needs to be abandoned. Scientists should be both free to speculate and humble enough to admit their theories may be wrong.