SPSG #6: Two Charades

While the earlier chapters are largely historical, this is the chapter that begins to speak of current practice, and it is also gives the book its title. Quite simply, the Science-Policy Shell-Game (SPSG) is a technocratic game played by treating science and policy as if they were interchangeable in both directions. It is comprised of two components. On the one hand, a statement is purported to be science in front of a political audience. On the other hand, the same statement is purported to be policy in front of a scientific audience. As the end result, a regulatory decision is shielded from both scientific and political scrutiny. Although there were many examples of it before, the SPSG was deliberately institutionalized by a committee of EPA technocrats in 1986. The object of their creation was the EPA Reference Dose (RfD). As an example of the Safety Assessment Paradigm, the RfD was no different from the ADI, except for one thing: It was claimed to be a scientific fact. As a further technocratic assault, the 2005 EPA Cancer Assessment Guidelines replaced plausible worst-case estimates with what amounted to a ban on theoretical reasoning. That was accomplished by interposing a "Point of Departure" between toxicological theory and regulatory decision making. That made no sense then, and it still doesn't. Why the SPSG is played is debatable; it may be some combination of agency managers hiding decisions they would rather not defend, scientists who don't want to cede regulatory control to agency managers or elected officials, statistical decision theorists who claim to make decision processes objective, or it may just be career maintenance and research dollars. But whatever the reasons are, the SPSG is antiscientific and antidemocratic. It cuts off scientific discussion from policy making with technocratic short cuts, and it leads scientists and the public to believe that the decisions faced by the government and themselves are far simpler than they really are.  The “Fifth Branch” is introduced as a term to describe the technocrats inside and outside of the federal government who play the SPSG.