To be true to your new directive, Mr. Pruitt, you need to fire Michael Dourson today

Richard Denison, a Lead Senior Scientist.

[Use this link to see all of our posts on Dourson.]

EPA Administrator Scott Pruitt issued a directive today that prevents independent scientists who receive research grants from EPA from serving on any EPA advisory panels.  Wholly unaddressed by the directive is any counterpart prohibition on scientists funded by industries with conflicts of interest from serving as EPA advisors.  

If Pruitt firmly believes that receipt of EPA funding is a basis for disqualifying a scientist from advising the agency, then he need look no further for someone to purge than his own recently named “advisor to the Administrator” on chemicals, Michael Dourson.

When it comes to advice the agency receives, the core concern over the need to avoid conflicts of interest is this:  Is advice tainted because the entity employing and paying the advisor stands to gain or lose financially from the agency decision that is under advisement?  Say, for example, EPA selected as an advisor a consultant to Koch Industries who it paid for work that concluded the company’s releases into the environment of the petcoke generated by its facilities are safe.  A reasonable person would have a basis to believe that Koch could benefit financially from the advice its consultant might provide the agency.  In contrast, how does EPA stand to benefit financially from the results of research conducted by an EPA-funded scientist?  The simple answer is, it doesn’t.

Now let’s look at it from the perspective of the scientist receiving the funding.  Pruitt’s directive is based on the outlandish premise that EPA funds research in order to find problems it can then regulate, and hence that an EPA-funded researcher has an incentive to find a problem in order to better ensure continued EPA funding.  The claim is that the advice offered by that researcher would be “pre-tainted” toward supporting EPA policy decisions that drive regulation.  This theory that imagines a grand conspiracy between researchers and the agency is inherently flawed and unfounded.  

First, it ignores the fact that a distinctly non-regulatory part of EPA – the Office of Research and Development – funds virtually all of EPA’s extramural research.  ORD is intentionally a separate entity within EPA that manages science issues, precisely to provide some degree of separation from the program offices that make regulatory decisions.

Second, it ignores the process by which the agency’s research dollars are awarded.  These grants are competitive and grant applications undergo peer review by outside scientists – just like research grants funded by the National Science Foundation or the National Institutes of Health.

Third, the results of EPA-funded extramural research must undergo another round of peer review in order to be published.  To the extent Pruitt believes that EPA researchers conduct unsound science just in order to find a problem EPA can regulate, there are safeguards the scientific community adopted long ago and continues to refine to prevent such scientific fraud or misconduct and punish it severely.

Folks, this is how public sector-funded science works across virtually every field of human inquiry.

But don’t take my word for the strength of EPA-funded research:  Just this year, the National Academy of Sciences (NAS) published a review of the agency’s main research program, called “Science to Achieve Results” (STAR).  That review effectively raved about the program.  Among its conclusions:

  • EPA has high-quality procedures for priority-setting that allow STAR to be integrated within EPA's research program.
  • STAR's procedures to develop funding announcements and award grants ensure that the program sponsors research of high scientific merit.
  • Research proposals are subject to thorough peer review, and conflicts-of-interest checks are extensive and embedded throughout the peer review process.
  • The STAR program is productive. The committee found that the results of the research the program funded have led to numerous public benefits, including:
    • development of an environmental-science workforce,
    • development of human-resources and research infrastructure across the nation,
    • a potential reduction in the costs of compliance with environmental regulation, and
    • provision of the scientific basis of decisions required to protect public health and the environment.

Is Pruitt now going to impugn the integrity and objectivity of the NAS – the nation’s leading scientific body??

Which brings us back to Pruitt’s directive and the real motivation behind it:  to skew the advice EPA receives heavily in the direction of supporting the anti-science and anti-public health agenda he is aggressively implementing.

So what does all of this have to do with the provocative headline I gave to this post?  If Pruitt firmly believes that receipt of EPA funding is a basis for disqualifying a scientist from advising the agency, then he need look no further for someone to purge than his own recently named “advisor to the Administrator” on chemicals, Michael Dourson.  Pruitt made that appointment so that Dourson could start work at the agency (he started two weeks ago) even though his nomination to head the chemical safety office at EPA has yet to be confirmed by the Senate.  Dourson has repeatedly touted the fact that he and his company Toxicology Excellence for Risk Assessment (TERA) were funded by EPA.  Just look at their annual reports.

Pruitt seems just fine with ignoring Dourson’s extensive conflicts of interest involving his work for companies to exonerate their chemicals – companies and chemicals he would be charged with regulating if confirmed to his leadership post at EPA.  Pruitt certainly didn’t let such things bother him when clearing his political deputy Nancy Beck of any ethical conflicts based on the astounding ethics agreement that gives her wide latitude to work at EPA on issues in which her immediately preceding employer the American Chemistry Council (ACC) has financial interests – in order to ensure those interests are taken into account.

My guess is Pruitt will just as readily ignore the fact that Dourson should be Exhibit A under his new directive.  But then, the bar for hypocrisy has never been set lower than under this administration.


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