{"id":6884,"date":"2017-09-18T10:07:49","date_gmt":"2017-09-18T15:07:49","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=6884"},"modified":"2024-02-12T11:02:00","modified_gmt":"2024-02-12T16:02:00","slug":"modus-operandi-how-epa-toxics-nominee-dourson-carries-out-his-work-for-the-chemical-industry","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2017\/09\/18\/modus-operandi-how-epa-toxics-nominee-dourson-carries-out-his-work-for-the-chemical-industry\/","title":{"rendered":"Modus operandi: How EPA toxics nominee Dourson carries out his work for the chemical industry"},"content":{"rendered":"<p><em>Richard Denison, Ph.D.,\u00a0<\/em>is a Lead Senior Scientist.<\/p>\n<p><em>[Use <a href=\"https:\/\/blogs.edf.org\/health\/tag\/dourson\/\">this link <\/a>to see all of our posts on Dourson.]<\/em><\/p>\n<p>I\u2019ve now examined dozens of papers and reports that EPA toxics nominee <a href=\"https:\/\/blogs.edf.org\/health\/tag\/dourson\/\">Michael Dourson <\/a>and his firm, Toxicology Excellence for Risk Assessment (TERA), have published on chemicals over the past 15-20 years.\u00a0 A remarkably consistent pattern of how Dourson conducts his paid work for the chemical and pesticide industries emerges from this examination.\u00a0 I\u2019ll use one example below to illustrate, but most or all of the steps I\u2019ll describe have been followed over and over again. \u00a0<!--more--><\/p>\n<p>The example I\u2019ll use relates to two herbicides, alachlor and acetochlor (collectively known as acetanilides), widely u<a href=\"https:\/\/blogs.edf.org\/health\/wp-content\/blogs.dir\/11\/files\/2017\/09\/Alachlor-and-acetochlor-use-maps-USGS-2012.png\"><img loading=\"lazy\" decoding=\"async\" class=\"alignright wp-image-6889 size-thumbnail\" src=\"https:\/\/blogs.edf.org\/health\/wp-content\/blogs.dir\/11\/files\/2017\/09\/Alachlor-and-acetochlor-use-maps-USGS-2012-150x150.png\" alt=\"\" width=\"150\" height=\"150\" \/><\/a>sed in huge volumes especially in the Midwest.\u00a0 The US Geological Survey reported that in 2015 about <a href=\"https:\/\/water.usgs.gov\/nawqa\/pnsp\/usage\/maps\/show_map.php?year=2012&amp;map=ALACHLOR&amp;hilo=H\">2 million pounds of alachlor <\/a>and <a href=\"https:\/\/water.usgs.gov\/nawqa\/pnsp\/usage\/maps\/show_map.php?year=2012&amp;map=ACETOCHLOR&amp;hilo=L\">more than 40 mill<\/a><a href=\"https:\/\/water.usgs.gov\/nawqa\/pnsp\/usage\/maps\/show_map.php?year=2012&amp;map=ACETOCHLOR&amp;hilo=L\">ion pounds of acetochlor<\/a> were used in agriculture annually. The USGS map images included here (click to enlarge) show where these substances are used, based on 2012 data.<\/p>\n<p>Dourson\u2019s work specifically addressed the degradation products of alachlor and\u00a0acetochlor, which are frequently detected in ground and surface waters.\u00a0 Except as otherwise noted below, the specifics I describe are recorded in documents posted on TERA\u2019s <a href=\"http:\/\/www.tera.org\/ART\/Degradates\/index.html\">webpage for this activity<\/a>.<\/p>\n<p><strong>STEP 1:\u00a0 The process typically starts with a company or industry that has a problem or a decision it wants to influence<\/strong>, e.g.:\u00a0 a chemical has been spilled or is showing up in air or water monitoring; a facility permit is being reviewed; a government agency is doing a risk review of a chemical or updating a standard.\u00a0 In this case, Dow AgroSciences and Monsanto, makers of the acetanilides, were facing growing scrutiny as the herbicides\u2019 degradation products were being routinely detected in ground and surface water samples and regulators in states like <a href=\"http:\/\/www.mda.state.mn.us\/chemicals\/pesticides\/acetochlor1\/acetochlor6.aspx\">Minnesota<\/a> were reviewing applicable water standards.<\/p>\n<p><strong>STEP 2:\u00a0 The affected company or industry group <\/strong><strong>contracts with TERA to convene an \u201cexpert\u201d panel or workshop or conduct a peer<\/strong> <strong>review<\/strong> of a government or industry assessment, research plan or other document.\u00a0 TERA is hired to convene and manage the panel or peer review.\u00a0 In this case, Dow AgroSciences and Monsanto hired TERA to run a workshop involving an \u201cexpert\u201d panel that TERA was also to select.<\/p>\n<p><strong>STEP 3:\u00a0 TERA appoints its own founder and President, Michael Dourson, to the panel, almost always as Chair of the panel.<\/strong>\u00a0 This is a highly questionable practice:\u00a0 While the selection of panels and peer reviewers is sometimes contracted out to \u201cthird parties,\u201d the <a href=\"https:\/\/www.epa.gov\/osa\/conflicts-interest-review-process-contractor-managed-peer-reviews-epa-highly-influential\">procedures used <\/a>are designed to keep the entity identifying experts and managing panels and associated meetings at arm\u2019s length from the experts themselves.\u00a0 TERA makes no such effort:\u00a0 In the acetanilides case, as in the great majority of other TERA cases, employees of Dourson\u2019s own company appointed him (their boss) to chair the \u201cexpert\u201d panel.<\/p>\n<p><strong>STEP 4:\u00a0 TERA clears Dourson of any conflict of interest in his participation on the panel.<\/strong>\u00a0 That is, employees of Dourson\u2019s own company are the sole determiners as to whether or not their boss has a conflict of interest in the matter at hand.\u00a0 Highly irregular, to say the least, an approach that presents its own conflicts of interest.\u00a0 In the acetanilides case, TERA cleared Dourson to serve on the panel even though TERA had recently contracted with both Dow AgroSciences and Monsanto to \u201cprovide technical review on projects.\u201d\u00a0 This is not an isolated incident:\u00a0 In numerous other cases, TERA or Dourson himself had recently worked for the very same company or industry group paying TERA to convene a panel or conduct a review in which Dourson participated, typically as Chair.<\/p>\n<p><strong>STEP 5:\u00a0 Based on the workshop or review, Dourson and his colleagues write a paper for publication, sometimes involving other workshop or panel participants.<\/strong>\u00a0 In the acetanilides case, the first 5 of the 9 authors on the paper (including Dourson) were TERA employees.<\/p>\n<p><strong>STEP 6:\u00a0 The paper is typically published in the industry\u2019s go-to journal, <em>Regulatory Toxicology and Pharmacology<\/em>.<\/strong>\u00a0 I have <a href=\"https:\/\/blogs.edf.org\/health\/2017\/08\/09\/doursons-go-to-journal-for-publishing-his-industry-funded-papers-is-well-also-industry-funded\/\">blogged earlier <\/a>about the large fraction of Dourson\u2019s papers \u2013 well over half \u2013 published in this one journal, which has a longstanding reputation of being the go-to journal for both tobacco and chemical industry-friendly paper publishing.\u00a0 The journal has been the subject of numerous expos\u00e9s over the past 15 years regarding its close ties to the chemical and tobacco industries.\u00a0 True to form, in this case, Dourson\u2019s <a href=\"http:\/\/www.sciencedirect.com\/science\/article\/pii\/S0273230010000395\">paper <\/a>was published in <em>Regulatory Toxicology and Pharmacology<\/em>.\u00a0 It recommended water quality standards for acetanilide degradation products many times less protective than those in place in <a href=\"http:\/\/dnr.wi.gov\/topic\/drinkingwater\/documents\/haltable.pdf\">Wisconsin<\/a> and <a href=\"http:\/\/www.health.state.mn.us\/divs\/eh\/risk\/guidance\/gw\/table.html\">Minnesota<\/a>.<\/p>\n<p>Not all of these steps have occurred with every chemical.\u00a0 Dourson\u2019s work on the likely carcinogen <a href=\"https:\/\/blogs.edf.org\/health\/2017\/09\/06\/report-widespread-exposure-to-a-risky-chemical-blessed-by-the-trump-administrations-nominee-to-head-epas-toxics-office\/\">1,4,-dioxane<\/a>, for example, paid for by PPG Industries, doesn\u2019t appear to have relied on an intervening workshop or \u201cexpert\u201d panel for cover, and instead went straight to publication of a <a href=\"http:\/\/www.sciencedirect.com\/science\/article\/pii\/S0273230014000129\">paper<\/a>, once again in <em>Regulatory Toxicology and Pharmacology<\/em>.\u00a0 Not surprisingly, here too he argued for a far less health-protective standard, in this case about 1000-fold weaker than EPA\u2019s level indicating an increased cancer risk.\u00a0 It\u2019s worth noting that state agencies in <a href=\"http:\/\/www.michigan.gov\/documents\/deq\/deq-aqd-toxics-14-DioxaneTSG_Report_2015_487415_7.pdf\">Michigan <\/a>and <a href=\"http:\/\/www.state.nj.us\/dep\/dsr\/supportdocs\/11-chemicals-response.pdf\">New Jersey<\/a> reviewed Dourson\u2019s work on this chemical and found it sorely lacking on scientific grounds.<\/p>\n<p>It is not only Dourson\u2019s deep conflicts of interest that lead us to oppose his nomination, but also his questionable science and incessant claims of independence, when in fact his whole step-by-step enterprise has been set up to bend the science in support of the interests of his corporate clients.<\/p>\n<hr \/>\n<p>Current EPA political appointees already include a number of industry insiders.<br \/>\n<a href=\"http:\/\/www.edfaction.org\/sites\/edactionfund.org\/files\/trumps-epa-polluters-all-star-team.pdf\"><strong><u>Click here to see brief thumbnails on individuals who have already been installed.<\/u><\/strong><\/a><\/p>\n","protected":false},"excerpt":{"rendered":"<p>Richard Denison, Ph.D.,\u00a0is a Lead Senior Scientist. [Use this link to see all of our posts on Dourson.] I\u2019ve now examined dozens of papers and reports that EPA toxics nominee Michael Dourson and his firm, Toxicology Excellence for Risk Assessment (TERA), have published on chemicals over the past 15-20 years.\u00a0 A remarkably consistent pattern of &#8230;<\/p>\n","protected":false},"author":100,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[44,5009,56093,114108],"tags":[91812,68],"coauthors":[],"class_list":["post-6884","post","type-post","status-publish","format-standard","hentry","category-policy","category-health-science","category-industry-influence","category-tsca","tag-dourson","tag-epa"],"acf":[],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/6884","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/users\/100"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/comments?post=6884"}],"version-history":[{"count":1,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/6884\/revisions"}],"predecessor-version":[{"id":12806,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/6884\/revisions\/12806"}],"wp:attachment":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media?parent=6884"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/categories?post=6884"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/tags?post=6884"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/coauthors?post=6884"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}