Alan Moghissi is one of America’s best known and most respected scientists. He witnessed the birth of the Environmental Protection Agency (EPA), a sprawling and fearsome federal agency created in 1970 through the merger of parts of 13 federal agencies, including the U.S. Public Health Service.
At the time, Dr. Moghissi was Director of Research at the Service’s laboratory in Las Vegas, where he was studying the environmental impacts of nuclear weapons testing in the Nevada desert. Over the next 15 years, Dr. Moghissiheld several important EPA posts: Director of theBioenvironmental / Radiological Research Division, Principal Science Advisor for Radiation and Hazardous Materials and Manager of EPA’s Health and Environmental Risk Analysis Program.
Dr. Moghissi was born in Iran, but educated in Switzerland and Germany. He is a graduate of the University of Zurich, the Federal Institute of Technology, also in Zurich, and the Technical University of Karlsruhe (nowKarlsruhe Institute of Technology) in Germany, where he earned a PhD in physical chemistry.
Moghissi is an honorary member of the National Council on Radiation Protection and Measurement, a member of the International Academy of Indoor Air Sciences, an Academic Councilor of the Russian Academy of Engineering, and an Academic Councilor of Universidad Popular Autonoma del EstadoPuebla in Mexico. He is a Fellow of the American Society of Mechanical Engineers, a unique honor for one who is not a mechanical engineer. He is also the recipient of many awards, including the EPA’s Distinguished Carrier Award.
Then Secretary of State, Colin Powell, appointed him to a Commissioner’s seat on the U.S Commission to the United Nations Educational, Scientific and Cultural Organization (UNESCO), a position to which the subsequent Secretary of State, Condoleezza Rice, reappointed him. He has also served on numerous national and international panels, including the U.S. Committee on the International Hydrology Programme.
Dr. Moghissi has served in numerous academic capacities: Associate Vice-President for Environmental Health and Safety at Temple University in Philadelphia and Assistant Vice President for Environmental Health and Safety at the University of Maryland in Baltimore, where he also served as a Professor of Medicine. He was a visiting professor at Georgia Institute of Technology, Atlanta, and the University of Virginia in Charlottesville. He was also affiliated with the University of Nevada at Las Vegas and the Catholic University of America in Washington, D.C. He is an Adjunct Professor in the School of Medicine at Georgetown University in Washington, D.C., and a Senior Research Fellow at George Mason University in Fairfax County, Virginia, and he is a member of the Board of Regents and a Senior Fellow at the Potomac Institute for Policy Studies in Washington D.C., an organization that assists decision makers in developing polices based on sound science.
Dr. Moghissi is currently the President of the Institute for Regulatory Science [RSI], a non-profit organization he founded that is dedicated to the idea that societal decisions must be based on Best Available Science (BAS) and Metrics for Evaluation of Scientific Claims (MESC) based on BAS. RSI’swork includes research, independent peer review of scientific projects, scientific assessment, and science education at all levels, especially the education of minorities.
The depth and breadth of Moghissi’s research is impressive, and includes the development of the BAS/MESC concept and its relevance and application to the scientific foundations of laws, regulations, judicial decisions, and public education. He has published several books, more than 400 papers and at least 300 reports based on peer reviews and scientific assessments that he personally led. His work has been sponsored by several national and international organizations and governments, including the U.S. Congress.
Moghissi has testified numerous times before U.S. House and Senate committees, most recently last November, when he appeared before the Subcommittee on Energy and the Environment of the U.S. House Committee on Science, Space and Technology. The title of his presentation was “The Need for Regulatory Science Transparency at the EPA.”
Moghissi also served as Editor-in-Chief of for Environment International, Waste Management and Technology, a publication that traces its origins to the Journal of the Franklin Institute, one of the oldest technical journals in the United States. He is currently spearheading development of a new journal, Regulatory Science and Technology.
Dr. Moghissi is a bedrock believer in the principle that, in representing society’s interests, our government must base its policy decisions on Best Available Science – meaning science that has passed successfully though rigorous independent peer review. He is thus lending his time and considerable scientific credibility to the formation of the Environmental Sciences Independent Peer Review Institute (ESIPRI), a new and ambitious non-profit organization based in Port Townsend, Washington.
ESIPRI, which is the focal point of the current special edition of Evergreen Magazine, has set its sights on providing an impressive array of third party peer review services to governments and industries. For reasons having to do with the U.S. employer obsession with youth, otherwise known as age discrimination, Dr. Moghissi refuses to divulge his age.
But he came to the United States in 1963 under the aegis of Operation Paper Clip, a long-running Department of Defense (DOD) program designed to bring the best scientific talent in the world to the U.S. after World War II. Among its legendary finds: the late Werner Von Braun, principal architect of the U.S. space program. DOD recruited Moghissi after he published a widely praised paper on uranium isotopes.
Suffice it to say, when ESIPRI’s Board of Directors invited us to talk to Moghissi, we jumped at the chance tointerview him in his Alexandria, Virginia home. He is an engaging and good humored man, a classically trained violinist who laughs loudly and brims with the energy and passion of a man half his age.
Evergreen: Tell us a bit about your early life.
I was born in Iran, but our family eventually moved to Switzerland. There were six siblings. All of us earned a doctorate degree of one kind or another. Apart from science, my life’s passion has been music. I am a classically trained violist, and I had a devil of a time deciding between careers in music and science. My father made the decision for me. In hindsight, it was the right decision.
Evergreen: Was school easy for you?
Yes and no. Although math was very easy for me, I was dyslexic, so I could not add or subtract because I could not distinguish “17” for “71” or “38” from “83.” I overcame it – Attention Deficit Syndrome – with the help of my loving mother and grandmother. I was a curious boy who questioned everything. It is a habit that has served me well as a scientist.
Evergreen: Are you still interested in music?
Oh, heavens yes. I love the classics, especially Beethoven’s Pastoral Symphony No. 6 in F major. It premiered in Vienna on December 22, 1808, and is thought to have been composed while he was walking through the Vienna Woods, which are similar to the Black Forest near where I spent much of my youth.
Music is my catharsis. It has helped me overcome my frustrations with the politicization of science, especially within the Environmental Protection Agency, which has squandered much of its hard-earned public credibility in numerous agenda-driven pursuits, including climate change and nuclear waste disposal.
Evergreen: How so?
It’s a long story, and I’m sure we’ll cover most of it in this interview, but let’s first acknowledge the fact that the EPA has done some excellent work in the air and water quality, and many other arenas since its formation in 1970. I know this because I was an EPA scientist for 15 years, beginning when the agency was formed. I was Director of Research at the U.S. Public Health Service laboratory in Las Vegas when the Service was folded into EPA.
Evergreen: Where did EPA lose its way?
When the EPA was formed it faced an avalanche of laws needing regulations. Historically EPA is given enough discretionary power to develop regulations using a mixture of proven science (information that anyone with right training and tools could reproduce) and the judgment of the staff. Over the years, with a few exceptions, there was no longer an urgent need for regulations but the staff continued the past habit and did not recognize the need for impartiality in formulating public policy. Many of them have personal agendas, which explains why the regulations they are writing often have an imbalance between proven science and their judgment.
During the first decades, the ratio of benefits to costs of EPA regulations was high, sometimes very high. Now the situation is reversed and the ratio is small and sometimes non-existent. It is why I am advocating for the Regulatory Science Sunshine Act, a proposal I have written that, in law, would require the EPA to develop scientifically sound processes, procedures, and methods for every regulatory decision they make. The public needs to be able to see and understand what the EPA is doing that impacts our daily lives.
Evergreen: But isn’t the EPA’s work too complicated for most people to understand?
At times, yes, but the solution isn’t to keep the public in the dark, which the EPA and its advocates seem to favor. Bill Ruckelshaus, who was EPA’s first Administrator, and my boss, used to remind us of Thomas Jefferson’s famous admonition to his colleagues, which I can still quote verbatim: “I know of no safe depository of the ultimate powers of the society but the people themselves; and if we think them not enlightened enough to exercise their control with a wholesome discretion, the remedy is not to take it from them but to inform their
The EPA is not informing the public’s discretion. It is hiding its work from independent scrutiny.
Evergreen: Was Ruckelshaus a good first EPA administrator?
Ruckelshaus was a nice person. He had to make decisions that were forced by legal mandates. He certainly made mistakes – banning DDT being the worst decision he ever made – but he was a nice guy and a capable administrator.
You have to understand that environmental advocacy was at fever pitch when he arrived on the scene. The prevailing view among environmental advocates was that our planet was dying and humans were the reason why. Of course, it wasn’t and still isn’t, but Ruckelshaus tried to accommodate their worries as best he could. For that reason, alone, many political conservatives did not like him.
Evergreen: Are you suggesting that politics has played a role in EPA’s growth?
Politics has played a huge role in EPA’s growth. Advocacy became a huge influence, even in my time. Those who were honest, and who did not wish to pander to environmental advocates’ alarmist claims, had a very difficult road to hoe. It is why I left the agency in 1985.
Evergreen: What were the circumstances of your departure from EPA?
I was director of the research portion of EPA’s health and environmental risk assessment program at the time. Over the objections of my superiors on the administrative side, I commissioned a study of ecological risk assessment – the main objection being their claim that it was not possible to define ecosystems. I disagreed. I also hired a second lab and asked them to quantify uncertainty in health risk assessment. Word of what I was doing soon got out and I was fielding dozens of calls from members of Congress who wanted to know more.
Evergreen: What did you tell them?
I told them that I believed it was possible to define ecosystems and measure the risks associated with the impacts our actions were having on the natural environment. Insurance companies use statistics to measure risk every day. It is how they set premiums for the life, health, and accident policies they sell in the marketplace.
Evergreen: What was the reaction from your superiors on the administrative side?
They weren’t very happy with me. The time soon came when I realized that, while I wanted to stay with EPA, the time had come for me to go. I thought it morally and ethically irresponsible for me to stay with the agency. I resigned a few days before Ruckelshaus resigned.
Evergreen: Has the EPA continued to insist that risk cannot be measured?
Let me rephrase your question: Is it possible to objectively quantify risk? Because in various stages of risk assessment the necessary information is not always available, the scientists must make assumptions and use judgments. These must be made based on science rather than ideology. Instead they make exaggerated claims. The worst of these claims is that the environment is fragile, easily destroyed, and irreplaceable. This is nonsense. Our natural ecosystems have countless built in redundancies. They are very resilient, despite claims to the contrary by environmental advocates.
Evergreen: Why do you think environmentalists make such exaggerated claims?
Let me answer this question by describing the distinction between two groups interested in environmental protection. The first group is ideologically driven and constitutes the core of environmental advocacy. The strategy of this group is to scare the public silly. It is how they make money and how they consolidate political power. The second group consists of individuals and organizations that I call ecological or environmental shepherds. As you know, shepherds take care of their herd, have dogs that protect the herd, ensure that the field has enough plants useable for herd, and many other activities. The shepherd lives on the farm and ensures its sustainability. Most unfortunately, this group has little or no influence because it does not scare people.
Evergreen: Can you give us an example of exaggerated claims by the EPA?
One of the worst ones for which I have personal knowledge is the regulation of exposure to ionizing radiation. EPA’s limit is 0.15 milliSievert (MSv) per year. The average natural radiation background in the US is about 3 mSv. The medical exposure is estimated to be anywhere between 0.5 to 3 MSv. Moving from Baltimore to Denver increases the radiation exposure several times higher than EPA’s regulatory limit. Where is the justification for the EPA’s limit?
Evergreen: How about climate change? Same problem?
Same problem. But let’s remember that clean air and clean water are worthy societal and regulatory goals. But we don’t have to tear down our economy to get there. What we must do is let science be our guide, and in this case, science tells us that if we want to get away from carbon dioxide [CO2] emissions that fossil fuels produce, we need to emphasize nuclear power, which is the cleanest energy source we have, and the only one that does not emit CO2 into the atmosphere.
Evergreen: Has EPA become a rogue agency?
Again, allow me to rephrase your question. Whenever we give a public agency the freedom and the money Congress has given EPA we can expect that the agency and its people will become increasingly arbitrary in their decision making. It is human nature.
Evergreen: Give us an example?
I can think of none more egregious than EPA’s decision to label CO2 an atmospheric pollutant. Without CO2, there would be no ecosystems. Yet EPA wrote a document, without independent peer review, and announced that CO2 is a pollutant that harms human health. And now they are writing the regulations that will have insignificant impact on global CO2. Currently, the U.S. contributes about 15-17% of global CO2 emissions, as compared to China with about 25%.
Evergreen: Is there any margin for error in their claim?
Within the next decades the BRIC nations - Brazil, Russia, India, and China - will substantially increase their CO2 emissions so that the US contribution will be at most 10% of the global emissions. Given this fact reducing the CO2 emissions in the US will have insignificant impact, even if the CO2 is assumed to be the cause of global warming. However, it would have major adverse economic consequences.
Evergreen: Who has oversight responsibility for the EPA?
The EPA has the status of a Department. As such, it reports to the President. Congress has the only true oversight. It can use the appropriations process or pass laws that limit and control EPA’s activities. For example, the Data Quality Act requires that the Office of Management and Budget [OMB] make certain that proposed new regulations with costs above certain limits are based on an appropriate cost benefit analysis. Unfortunately, EPA’s regulatory cost estimates are almost always underestimated.
Evergreen: Generally speaking, what do we learn from cost-benefit analysis?
We learn that the low hanging fruit is the cheapest to pick. Air and water quality regulations are a good example. The cost of, say, an 80 or 90 percent reduction in particulate air emissions or pollutants discharged into rivers isn’t high when you consider the alternative. But the cost of chasing pollutant amounts that are so small that we can’t reliably measure them using today’s best available science and technology can
be staggering. You have to ask yourself whether it’s worth it given the societal impacts – loss of jobs and tax revenue for example. Moreover, given the current situation at EPA, we don’t know what the beginning assumptions were – and if we don’t know what the assumptions were we can’t know what was saved or at what cost.
Evergreen: What was EPA’s reaction to your recent House testimony concerning the need for more transparency in its decision and rule making processes?
There has been no reaction, zero, nothing but silence. It is as though I never testified. Even people on my side, those who favor a rigorous, science-based policy making process, haven’t said much. I sensed that the Democrats on the committee did not know what to do with me. Of course, part of the problem stems from the fact that it would have taken hours for me to explain why a Sunshine Law is needed. Forcing the EPA to come clean on its own clandestine rulemaking agenda will not be easy.
Evergreen: We have all the time you will allow us. Why not walk us through your testimony?
Alright, but I first want to add to my earlier comments about Bill Ruckelshaus. I said earlier that environmental advocacy was at a fever pitch when the EPA was formed in 1970, and that was true. But Bill’s already challenging job was made even more difficult by the fact that Congress left too much to personal interpretation.
A lot of law and regulation was subsequently written in haste by people who were working very hard to meet mandated deadlines. The process wasn’t very tidy. Decision making based on discretion got out ahead of decision making based on science, and it’s pretty much
stayed there. During this time, the phrase “regulatory science,” was coined at EPA.
Evergreen: So is regulatory science a good place to start?
It’s as good as any. Not many know this, but the EPA has a very well-funded research and development program that, at least theoretically, forms the basis for its regulatory decisions. The program includes many scientific disciplines: toxicology, ecology, hydrology and the atmospheric sciences. The approach is similar to that which is used to segment other scientific disciplines, including chemistry, which covers organic and inorganic chemistry, biochemistry, physical chemistry, chemical engineering, and medicinal chemistry. All we’re really talking about here are fields of inquiry based on more refined scientific activities.
Evergreen: It sounds simple enough.
It is in an organizational sense, but at EPA the process isn’t sufficiently transparent. The agency almost always substitutes its own assumptions whenever the scientific information it needs isn’t there or is incomplete. It also makes judgments in applying what scientific information it has to specific needs. And it uses default data - meaning it arbitrarily picks numbers it likes if the values it needs are not available from reliable sources. The regulated community – business and industry – and the scientific community - have the right to know what assumptions and judgments were made, what default data were used, and what would happen to the EPA’s conclusions if other assumptions, judgments and default data were applied?
Evergreen: Not so simple after all?
No, it isn’t. One of the most often violated requirements of regulatory science is the government’s inclusion of societal objectives and ideological objectives in science. Regulators claim they must include these non-scientific objectives to protect human health, the ecosystem and numerous other goals. What is overlooked is that all of these goals, as desirable as they may be, are outside the purview of science and must be made after the science is resolved. This is why my Sunshine Law is needed.
Evergreen: It sounds as though the process by which regulatory science is developed needs to be tightened up?
This is true. I spent most of my EPA career working with colleagues to develop a systematic approach for evaluating science information. And we’re still working on it.
Evergreen: And what exactly has your work included?
We had to identify fundamental underlying principles, not just for regulatory science but, equally important, principles for assessing the reliability of scientific claims regardless of their source. Finally, we had to find a way to separate science from issues that fall outside the purview of science, and we had to find ways to assess the maturity of scientific information that is being used to promulgate regulations.
Evergreen: You’ve been at it a long time?
More than 40 years. Out of my work and that of many others has come a process for identifying “best available science” [BAS] and a system for evaluating it called “Metrics for Evaluation of Regulatory Science Information,” (MERCI). MERCI is actually the outcome of our earlier BAS work and both BAS and MERCI have, in turn, led to our advocacy for an independent peer review process.
Evergreen: Why is an independent peer review process needed?
To protect the integrity of the entire process, including the selection of Best Available Science as well as the metrics that are used to evaluate the science the EPA is using as a basis for the regulations it is writing.
Evergreen: What are these metrics that you reference?
There are five unambiguous principles – rules if you will – that must be followed in evaluating the science that justifies regulation. The first is open-mindedness. Science evolves as new research and new technologies tell us more about a particular subject or discipline. The EPA and the public must be willing consider new knowledge and new scientific claims.
The second is skepticism. All scientific claims should be approached with a good deal of old fashioned skepticism. Hence, those who make scientific claims must be willing to provide supporting evidence that builds confidence and trust.
The third is the universal scientific principle. It embodies a set of principles and standards that are basic to all scientific inquiry. A good example would be gravity. We’ve all heard the story of Newton’s apple tree, and we know that no matter where we are on earth, apples fall from the tree in the same predictable manner. So we know gravity exists and that its pull is the same everywhere, except inside atoms, but that is a story for later.
The fourth principle is transparency. Those who make claims have an ethical obligation to identify the maturity and reliability of the science that supports their claim.
The fifth and final principle is reproducibility. Those who make claims based on science must be able to reproduce their science. This is the proof of their claim.
Evergreen: These principles seem pretty straightforward.
Well, you’d think so, but you would be amazed by the number of EPA regulations that don’t meet these basic requirements. I mentioned the EPA’s decision to write rules regulating CO2 emissions based on the claim that CO2 is harmful to human health. As I said earlier, the EPA today has a political agenda that doesn’t have much of anything to do with science.
Evergreen: What is science and how do we do it?
Let’s divide your question into two parts, what is science and then how it is done. It may be easiest to define science by first defining what it isn’t.
Science isn’t ideologically driven and it has no agenda. It isn’t based on someone’s judgment, opinion or values, nor is it based on someone’s wishes, hopes, or feelings. Science is the unceasing search for knowledge. It begins with observation from which hypotheses are developed, tested, and finally proven or disproven. It is dispassionate, cold-eyed, robust, wide-ranging, exacting, open-minded, skeptical, transparent, reproducible, explainable, and non-partisan.
Evergreen: Is there a hierarchy or classification system for scientific information?
Yes, there is. Proven scientific Information [SI] is reproducible, predictable and reliable. Gravity and the speed of light fall into this category. So does the fact that the earth is round, not flat, and that our planet revolves around the sun. The overwhelming majority of all SI, including regulatory science, falls into Evolving SI. This class of SI ranges in terms of maturity, reliability, and other relevant factors from Reproducible SI to Partially Reproducible SI, and eventually to judgment and speculation. Then we have junk science or pseudo-science, which is information given to regulators by special interest groups.
Evergreen: Is science today fulfilling its societal role?
Yes and no. The medical and engineering sciences are largely fulfilling their roles, but many other sciences, including a segment of the environmental sciences including ecology and several other disciplines, are failing us. The reason is that the only way you make money in science is to first make exaggerated claims in the hope that you can scare the public into funding your agenda-driven research. This is the case with climate change, nuclear waste disposal, and endangered species listings.
Evergreen: How so with endangered species listings?
Again, we have here agenda-driven regulation, bypassing rigorous scientific inquiry or, more importantly, independent peer review of the SI that forms the basis for regulation. You are from the Pacific Northwest. The northern spotted owl listing is a classic example. I would love to conduct an independent peer review of the government’s decision to list the owl as a threatened species.
Evergreen: Many documents supporting the listing decision were destroyed by the government. Where would you begin?
I would first test the statistical validity of the assumptions made by the government’s scientists. The listing decision may have been justified, but before we can know if it was justified we must first determine whether the principles we discussed earlier – transparency, skepticism, open-mindedness, and reproducibility – were followed. An independent peer review would either justify the listing decision or prove it in error. There is no other way to know.
Evergreen: How is statistical validity determined?
By testing the underlying mathematical assumptions that support the scientific claims that are made in the report we are reviewing. The mathematics need to be expressed in a written format that can be understood and verified by independent peer reviewers. This is why
my Sunshine Act is needed. It forces EPA – in fact all government agencies – to explain their work in plain English. I know this sounds complicated, but it isn’t.
Let’s say that I tell you that I am such a fine fisherman that I can predict the number and size of fish I will catch in my favorite fishing holes on any given day. If it turns out that my predictions are accurate 90 percent of the time, I’m a pretty good fisherman and you can make public policy on the basis of my predictions. But if it turns out the my predictions were only 45 percent accurate, I still need a lot of practice and
you should not be making public policy based on my predictions.
Evergreen: Using your analogy, how would you rate the EPA’s fishing skills?
The current EPA would have difficulties proving that it is a good fisherman. You best stop at the store and gets some steaks for dinner or
you’ll go hungry tonight!
Evergreen: Is EPA’s political agenda anti-business?
Some who work at EPA are definitely anti-business, but many others are not. The more relevant question is, “Are EPA’s regulations so complex that compliance is virtually impossible?”
I spent years writing regulations and none of them were difficult to understand. But when you build up layer upon layer of regulation that often conflicts with other regulations, you have a big problem in the making. It is now possible to spend years, and millions of dollars, attempting to master EPA compliance only to discover that the regulations that apply to your business or industry are subject to the value judgments of someone at EPA, or of a federal court judge who sees the regulations in a very different light. This is wrong – and it speaks volumes for the need for regulatory transparency which can only be assured by forcing the EPA to explain its decisions in plain English.
At the risk of belaboring a point I’ve already made, this is why my Sunshine Act is needed. Businesses and citizens should not have to guess about what the regulations require.
Evergreen: We suppose many who work in resource-based businesses will want to support your proposal, but how?
By staying engaged in the political process. Our side – those who believe federal policies should be based on Best Available Science and believe in environmental shepherding – got discouraged and left the playing field some time ago. This is unfortunate because the government’s scientists are not high priests and they are not sacrosanct. Although I have respect for many of them, I know many scientists working in private industry or academia are better qualified than the government’s scientist, but they’ve gone underground because they don’t want to appear to be biased or partisan. The result of their silence is that our society is now subjected to a constant barrage of misinformation and disinformation based on junk science.
Evergreen: Didn’t Bill Ruckelshaus challenge the scientific community to find its voice?
He certainly did, and there was a reason why. Again, you must remember that Congress tasked Bill with finding ways to peacefully reconcile the cultures and traditions of 13 different federal agencies, each with its own research arm. And he had to do it amid a lot of political unrest and a dearth of reasonably well done peer reviews. In some cases, his starting point was limited to literature – basically propaganda - prepared by advocacy groups.
Evergreen: What did Ruckelshaus say to encourage scientists to step forward?
I remember him saying that nothing would erode public confidence faster than the suspicion that politically motivated policy considerations had been allowed to influence risk assessment. He was right. Earlier this year, I co-wrote a paper published by the Potomac Institute titled “The Ruckelshaus Effect” in which I quote him liberally. It’s here somewhere. Oh yes, here it is. Allow me to read some excerpts.
“…all scientists must make it clear when they are speaking as scientists – ex cathedra – and when they are recommending policy they believe should flow from scientific information… What we need to hear more of from scientists is science.”
“…the standards we set, whether technology or health, must have a sound scientific basis…risk assessment…must be based on scientific evidence and scientific consensus only.”
“…we should make uniform the way in which we manage risk across the federal regulatory agencies. The public interest is not served by two federal agencies taking diametrically opposed positions on the given health risk…”
“…scientists must be willing to take a larger role in explaining risks to the public – including uncertainties inherent in any risk assessment. Shouldering this burden is the responsibility of all scientists…”
Evergreen: Would we be correct in assuming that Ruckelshaus influenced the course of your research long after you and he left EPA?
That’s a fair statement. Although I did not always agree with Bill’s decisions, there is no doubt that his views led many of us down the path toward defining risk assessment. The National Research Council, which is the research arm of the National Academy of Sciences, teamed
with the National Academy of Engineering and the Institute of Medicine to produce a landmark report called the “red book” that made the critically important distinction between risk assessment, which is the purview of science, and risk management, which is the purview of
The stated purpose of risk assessment is to reduce the uncertainties associated with risk management decisions by comparing the range of available options for policymaker consideration. Unfortunately, today’s agendadriven EPA is not doing what needs to be done. As stated before, society has the right to know what assumptions or judgments were made, what default data were used, and why societal objectives
were included in the process. We also need to know what happens if other choices were made.
Evergreen: What has been the role of modern-day environmentalism in our federal government’s obsession with avoiding risk at all costs?
It is largely a philosophical role based on unproven assumptions. Modern-day environmentalism traces its origins to nineteenth century conservation, which was rooted in society’s acknowledgement that civilization could only move forward through its use and stewardship of natural resources. There is no denying that everything we have comes from the earth – our food, clothing, shelter, energy, medicines, and technologies, all of our wealth, both intrinsic and tangible. The conservation philosophy is the foundation of ecoshepherding as I described it.
In the early 1960s, the anti-nuclear weapons movement began to imbed itself in the environmental movement by advocating for the idea that nature knows best and that every species on earth has a right to an uninterrupted natural progression through its life cycle. In this scenario, human beings are just another species with no more right to impact an ecosystem than any other species. If you accept this hypothesis, you
are obliged to acknowledge the elephant standing in the middle of the room, and the elephant is a question and the question is, “If this natural system is so efficient, how come so many species have been lost through the millennia, millions of years before man appeared and
thousands of years before the Industrial Revolution began?”
The answer to this question is that the hypothesis is flawed. Nature is not some all-knowing or all-seeing force. Quite the contrary, nature is a terrible manager. It has no special knowledge or wisdom and it can’t make decisions for us. We must accept this responsibility and we must make our decisions based on Best Available Science, not value-laden political agendas.
Evergreen: You seem to be suggesting that ecosystems have both physical and social components?
They certainly do, but when our government diminishes social systems, as it does with Draconian regulations that lack scientific basis or public scrutiny, the opportunity and the social responsibility for finding science-based ways to reduce risk is lost. We end up with value-laden political agendas that deny society the right to solve its own problems. Environmental advocacy assumes most of us are too stupid or greedy to make good decisions by ourselves. This is morally and ethically wrong.
Evergreen: Can we insulate scientists – who are only human – from politicians and advocacy groups?
Of course we can. Independent peer reviews of the science underlying their policy decisions will provide them with all of the political cover they will ever need.
Evergreen: But aren’t some peer reviews rigged to insure the outcome?
Rigged is a strong word, but yes there are some scientists of the same value-laded persuasions that review one another’s work. These reviews have an inherent conflict of interest that no ethical scientist would ever tolerate.
Evergreen: Explain how independent peer reviews are supposed to work?
There are books that describe the process, including one I wrote. And there are manuals that take you through step by step. Allow me to summarize the process for you in short order.
The first question a peer review team must ask itself is, “Why are we doing this? What is our objective?” Once this question is answered to our satisfaction we develop review criteria. These are the all-important questions we hope to answer in the course of our peer review. It is vital that the questions be reasonably concise because if they aren’t we give ourselves too much latitude. Once we have our questions nailed
down, the job is to prove or disprove the veracity of the scientific claims we’ve been asked to examine.
Evergreen: Is independent peer review work expensive?
It can be, but the price can vary from a few thousand dollars for a simple review to a $500,000 for more complex reviews that require large multi-disciplinary teams.
Evergreen: Given the federal government’s propensity to allowing political agendas to influence its research programs, do you believe the government should get out of the research business?
No, I don’t. Some questions are simply too large to be addressed by private industry. But I do believe the government should also fund scientists who are skeptical about the government’s claims. The juried, independent peer review is the best – and only defense society has
against errant claims that lead to ultimately destructive policies.
Evergreen: What role should the press play in ferreting out government policies rooted in bad science?
Again, skepticism is the key. Unfortunately, many journalists take a lot of political baggage to work with them every day. I accept the fact that bad news makes headlines, but some of what is being reported is too damaging to society and the environment to be overlooked.
Evergreen: Can you give us an example?
Not long ago, three of my colleagues joined me in writing a paper titled the “Wakefield Effect,” in which we discussed the public fallout that accompanied Andrew Wakefield’s claim that he had scientific evidence that the measles-mumpsrubella (MMR) vaccine was causing autism
and a rare bowel syndrome in children. Wakefield, who was a British surgeon at the time, was joined by 12 other authors in a paper published in Lancet, a hybrid British medical journal that features both peer reviewed articles and general news features. Their paper,
which was published in 1998, turned out to be based on fraudulent claims. Worse, it caused mass hysteria among parents of small children – many of whom still refuse to get their children vaccinated despite the vaccine’s safety. For a time, the press fed on their hysteria.
Times reporter named Brian Deer looked into the matter that Wakefield’s many conflicts of interest, including financial, were uncovered. Lancet subsequently printed a retraction, but the damage lingers in the public consciousness. We can only wonder how many children are now at risk because they have not been vaccinated. It could have all been avoided if Lancet had subjected Wakefield’s paper to an independent review before publishing it, and the daily press had been more skeptical and less anxious to jump on Wakefield’s bandwagon.
Evergreen: At the risk of editorial comment, we have long believed the press erred in embracing the environmentalist claim that logging in old growth forests was pushing northern spotted owls to the brink of extinction.
I agree. The federal government’s decision to add the owl to its threatened species listing would make an excellent topic for independent peer review. Society’s social and ecological interests have not been well served.
Evergreen: Who are science’s heroes?
Oh my, such a question. Well, Einstein for sure for his general theory of relativity; Edison for the electric light bulb and so much more; Bell for the telephone; my friend and former Washington State governor, Dixie Lee Ray, for her work in nuclear waste disposal; Edward Teller, who I also knew, for his work in atomic energy ; Nobel laureate Willard Libby, for his work in radiocarbon dating, Von Braun, for rocketry and
pioneering our space program; John Bardeen for his work in semiconductors; George Washington Carver for his research in peanuts, soy beans, and sweet potatoes; and Nobel laureate Norman Borlaug, an awfully nice guy who I knew well, whose work in genetics and plant
pathology has probably saved billions from starvation.
Evergreen: What qualities do these scientists share?
Clearly, an unceasing devotion to the scientific process. Great discipline. Integrity. Courage in the face of adversity and discouragement. Less obvious, but no less important, is the fact that their contributions don’t begin and end with science. They also made remarkable and enduring contributions to the advancement of civilization.
Evergreen: Is science in decline? Are we losing these qualities in our scientific disciplines?
Science is not but certain scientists are in decline. Who can ever forget Trofim Lysenko, the pseudoscientist who was the director of Soviet biology under Joseph Stalin, and who destroyed Russian agriculture; or those who claimed that Jews and blacks are genetically inferior? Science eventually proved they were wrong. But fallacious information still exists, including numerous claims concerning politically charged environmental issues that lack any scientific basis. Even so, I continue to believe that the future looks very bright for science, especially in biomedical and Information technology fronts.
Evergreen: What can we do to regain lost credibility in the environmental sciences?
Forcing the EPA to justify its regulatory decisions on the basis of independently performed peer review would be a good place to start. And - as we discussed - the public needs assurances that all of the assumptions, judgments, default data, and areas outside the purview of science are identified and scrutinized. More broadly, our universities need to rededicate themselves and stop chasing agenda-driven research dollars from Washington, D.C.
Evergreen: You referenced ESIPRI a few moments ago. Why lend your name and considerable scientific credibility to a new organization with no track record? Why not a well- established group that has experience under its belt?
As I said a moment ago, the scientific foundation of environmental claims is in dreadful disarray. I am pleased that ESIPRI’s directors are stepping in and are willing or able to shore up the public’s dikes. That’s why I’m doing everything I possibly can to help ESIPRI get up and running.
Evergreen: Have you made any formal agreements with them concerning the use of your work?
I have asked only two things of ESIPRI: that they follow the principles laid out in my many writings concerning Best Available Science and that they utilize our metrics for evaluating regulatory science. They are also welcome to use all of the experience and knowledge we’ve gained through our Institute for Regulatory Science, and I have invited them to make use of our oversight committee, which follows peer reviewed principles and guidelines developed by the American Society of Mechanical Engineers.
Evergreen: Do you know anyone at ESIPRI?
I do. Bob Alverts, who is an ESIPRI board member, is a long-time friend. I’ve known him since his days with the Bureau of Land Management and U.S. Geological Service, where he had a long and distinguished career. It was he who brought ESIPRI to my attention. I trust his commitment to sound science, which is a good thing because I no longer have the time it takes to organize and manage these peer reviews.
Evergreen: What does ESIPRI need to do to build on your work?
I have been working on problems associated with Best Available Science and peer review for 40 years. From experience, I know that you have to stay at it, especially when you are alone and discouraged. If I have learned nothing else in my life as a scientist, I have learned that the truth has a marvelous way of eventually rising to the surface, just as it did in Nazi Germany at the end of the Second World War. Society must never give up in its pursuit of Best Available Science. ESIPRI can contribute much to this effort by holding the federal government’s feet to the fire.