Title: Science Community Opposes OMB’s Peer Review Proposal
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Section/SPIG: Occupational Health and Safety
Issue Date:
The Bush Administration’s efforts to permanently restructure the regulatory system, making it more difficult for future administrations to protect the environment and the public’s health, have run into opposition from a usually quiescent source: the science community.
Traditionally, the organizations that represent mainstream scientists and their research institutions have focused their Washington political efforts on research funding, avoiding involvement in policy fights which might be perceived as partisan. In recent weeks, however, the science community has displayed unusual unanimity and verve in its opposition to an attempt by the White House to impose a new centralized system for control of scientific information disseminated by federal agencies.
The scientific organizations are responding to an Office of Management and Budget (OMB) proposal innocuously called “Peer Review and Information Quality,” which attempts to limit what opponents of regulation have often called “regulation by information.” It is a predictable outgrowth of the strategy, perfected by the tobacco industry, that enables producers of hazardous products and pollution to delay formal regulation, and avoid compensating their victims.
Under the OMB proposal, all covered information put out by an agency would undergo some form of peer review, and any information that affects major regulation, or that could have a “substantial impact” on public policies or private sector decisions, would be put through a cumbersome system in which the information is reviewed by experts independent of the agency. Perhaps to slow the process further, the information (reports, Web pages, etc.) would first have to be published in draft form and disseminated for public comment, after which it would be sent to a peer review panel, along with the public comments. The agency would then formally respond to the peer reviewer’s comments before the information could be re-disseminated.
Peer review, or independent review by experts, is a pillar of the system of production of scientific information. Before articles describing the work of individual or small groups of scientists are published in scientific journals, the editors generally send the manuscripts to other scientists, who provide feedback and advice to the editor and the manuscripts authors. Many federal agencies have peer review mechanisms for the studies and reports they produce, either internally, or by outside experts.
But, as every scientist knows, peer review is a subjective process; it can be fair, or it can be stacked against you. The Bush Administration has already been chastised by the scientific community for stacking federal advisory committees with scientists beholden to regulated industries or right-wing interest groups. With the peer review proposal, the Bush Administration has gone further. Many of the nation’s leading academic experts could not be utilized, since the proposal excludes from participation those scientists whose research is funded by the agency involved. In contrast, the proposal does not preclude some industry-employed scientists from appointment to the panels.
It is clear from the categories exempted from the proposal that its targets are the programs that protect the environment and the public’s safety and health. Information related to national defense or foreign affairs is exempted, perhaps because accuracy isn’t so important in the matter of weapons of mass destruction and related issues. All permits are also exempted so that, for example, when a manufacturer submits its own studies to demonstrate the safety of a new pesticide, peer review isn’t necessary.
Much of this opposition from the science community was solidified at a remarkable workshop held in November at the White House’s request, by the National Academy of Sciences (NAS). Speaker after speaker, all invited as experts in regulatory sciences by the NAS, warned that the OMB proposal would lead to increased costs and delays in disseminating useful information and issuing rules that protect the environment and public health, while potentially damaging the existing system of scientific peer review. Many of the speakers challenged OMB to identify a single report or regulation that would have been improved had the proposed peer review system been in place.
It became clear at the meeting that the proposal reflected a fundamental lack of understanding of how science is used in regulation, and that the peer review model chosen by OMB is not particularly useful or even applicable to the process through which government agencies do their work.
Michael Taylor, who had served as FDA Deputy Commissioner for Policy, cautioned that the centralization of authority around peer review at OMB could have the unintended consequence of constraining public health officials from reacting to a national emergency.
Since the workshop, opposition to the White House proposal has continued to swell; not just from the public interest community that keeps a close watch on OMB, but from mainstream scientists. At its annual meeting in November, the American Public Health Association passed a resolution opposing the proposal. The American Association of Medical Colleges (AAMC), representing the nation’s schools of medicine, and the Federation of American Societies for Experimental Biology (FASEB) sent a scathing letter of opposition to the White House, as did the Council on Government Relations, representing more than 150 leading U.S. research universities.
The Bush Administration has made it a policy to appropriate widely used terms and give them new, often opposite meanings. The scientific community does not want the cherished term “peer review” to go the way of “clean skies” and “healthy forests.” In a recent editorial in Science magazine, Editor-in-Chief Donald Kennedy wrote that OMB’s labeling of this process peer review seems “strange,” and that the proposal contributes to the erosion of public trust in scientists.
The depth of the opposition of mainstream science to the White House proposal can perhaps best be seen in the letter NAS President Bruce Alberts sent to Graham. Representing the nation’s preeminent arbiter of science, Alberts warned in unusually harsh language that “the highly prescriptive type of peer review that OMB is proposing differs from accepted practices of peer review in the scientific community, and if enacted in its present form is likely to be counterproductive.”