Read on Twitter
1/8 EPA's transparency rule is poorly found and lacks evidentiary support. Example: "nor is this rule likely to result in decreased human health or environmental protections" - how would EPA know? They did no analysis to support this rule.
2/8 "EPA may still use the pivotal science after either giving it lesser consideration or receiving an exemption from the req'ts of this rule from the Administrator" - EPA is ruling that a political appointee, not an independent group of scientists, should make this decision.
3/8 "The EPA plans to promulgate either statute-specific
transparency regulations or programmatic actions implementing this procedural rule". Translation: EPA hasn't figured out what it will do, and just wants to throw stuff up on the wall to see what might stick.
transparency regulations or programmatic actions implementing this procedural rule". Translation: EPA hasn't figured out what it will do, and just wants to throw stuff up on the wall to see what might stick.
4/8 EPA "will give greater consideration to pivotal science for which the underlying dose-response data are available". This rule focuses on reproducibility - being able to obtain the same results with the same data and methods. That's not validation. Nor does it address rigor.
5/8 Overall “rigor” depends on:
o Application of scientific method
o Well thought-out plan, methodological best practices
o Extent of replication (e.g., studies of different design, independent execution, assessing different sources of variability)
o peer review
(etc.)
o Application of scientific method
o Well thought-out plan, methodological best practices
o Extent of replication (e.g., studies of different design, independent execution, assessing different sources of variability)
o peer review
(etc.)
6/8 Judgments regarding validity, value, and utility of science can be and are made via peer review. Scientists are trained in assessing research, including logic of the research design, clarity/appropriateness of methods , and appropriate citation of previous results, etc.
7/8 EPA has not explained how peer review has failed so catastrophically that this rule is a necessary intervention... having served on (pre-Trump) FIFRA SAP, SAB, CASAC... peer review actually worked fairly well and can be restored in the new administration
8/8 "the Agency may still consider these studies but will give them lesser consideration unless the Administrator grants an exemption". What is "lesser consideration"? This rule was poorly formulated and badly written, and is a mess. Undoing this mess should be a priority.
