Science and Regulation at the EPA Today. . .

The New York Times had an Op Ed piece this past week written by two former EPA officials discussing a new tactic being embraced by Scott Pruitt and they fear will be adopted by other regulatory agencies. 

Scott Pruitt’s Attack on Science Would Paralyze the E.P.A.

The new tactic in fighting or diminishing the EPA's regulatory regime is to challenge the science it is based upon. For Pruitt, the head of the EPA, (and also one of its biggest critics), and Republicans in Congress, transparency has become the rallying cry. You have to give them credit. Transparency. Has there ever been such an over-used word? Originally associated with the need for transparency in the halls of Congress and in financial transactions, Pruitt and the Republicans have now embraced and applied it to scientific research.

Actually it does seem like a reasonable request. Regulation should be based on publicly available science. It is not. Due primarily to two reasons: patient privacy rights, and intellectual property. In short we want to protect patients’ case histories being shared and discussed in public discussions. And the other is trade secrets, which in some cases businesses spent years and who knows how much on research to discover these drugs and chemical compounds. There is a reason they patent and protect such knowledge. Neither of these; neither patient details, nor patented products and copyrighted information should be shared and distributed publicly for obvious reasons.

Yet you do need to regulate these fields, these domains: the medical, the pharmaceutical and the chemical. The solution has been to engage in “secret science”, though peer reviewed, yet not publicly published, not publicly shared.

Pruitt and Republicans want to abandon this process of using non-published science. If it cannot be shared then it should not be the basis of regulation. There is a certain reasonableness to the request.

The consequence, however, is to simply abandon regulation. It basically forces regulators to use publicly available science. the challenge becomes with new research, new discoveries, there is little publicly available research. I don’t think any patients wants their medical records shared, though they might reconsider, considering the alternative, I.e. no or limited review of the research nor the resulting regulations to protect them from the new drugs and chemicals they are being offered.

Jump to the chemical industry which is regulated by Pruitt’s EPA. Due to their patents, the latest and greatest chemical compounds cannot be regulated. Insecticides, detergents, and the like, if they are new and we know little publicly, well the regulation will arrive in a few years, when we do have publicly available information. So out of a respect for the patent holder we must accept that we cannot have a regulatory regime. Not until we have publicly available research. What?

So in the the name of transparency pharma and the the chemical business have found an argument against not regulation, but the science that leads to it.

Ultimately, it comes down to trust. We traditionally and historically just trust science. We have up until now put our trust in the scientific method. In short, we have up  until now placed our faith in peer reviewed research or something close to it.

You have to give Pruitt and company credit. We boast about our peer reviewed research which typically entails journals. Yet we are compromising here.

Of course there must be some hypocrisy here also. Those same companies who developed those drugs and chemicals somehow developed them in secret. And yet the products are still considered the products of science.

At the root of this is an issue involving trust. Who do we trust? The pharma and chemical companies? Big government? Or the process we have created between the two? The later is an ongoing battle, between three parties. Those parties are pharma and chemical companies, the regulators, and the environmental groups. And the three of these will ultimately resolve this in court. So historically, we really have trusted that between these three, some good science, and a solid court system we would ultimately sort this out. and we acknowledge that project is never done. 

One does, however, pause when the validity of the science is questioned. And this is a common theme today. Yet perhaps a bit of skepticism is a good thing. To challenge and review the work done and considering how it is done, what is the actual process embraced by the scientists, is a good thing. The process we have in place will either stand and be reinforced by such a challenge or we will find the bugs and ultimately enhance the process. 

So despite my concerns about this assault on science and the issue of eliminating regulation based upon this attack, I do still have faith in the overall system and specifically our courts.I know that the environmental groups will not allow this without a court battle. So this will be sorted out, and I am pretty certain that science will continue to drive a proper regulatory regime. And I do see a certain legitimacy to the challenge of transparency and its lack in a secret science, That said, I am annoyed that they even try to challenge it. It being science. How could they(?) is my response.

So I wonder in the end if I am perhaps a bit dogmatic in my acceptance of science? It is perhaps a blind spot? It is possible that the EPA is doing shitty secret science? It would not be the first time, And Pruitt, the environmentalists, and the courts will sort through that and proceed. That is the hope. So yes I have little little use for Pruitt, and I do believe he is basically attempting to destroy and sabotage the very agency he supposedly directs and manages. 

That said, this exercise of looking at various processes and procedures might actually be a good thing. We might just find some issues, and will get to find out how resilient the system is, even with or especially with people on the inside trying to blow it up. 

This might truly be a case of that which does not kill us or the EPA, will make us or the EPA stronger. Maybe.

Why Dumbass?

My last post was titled, "Some dumbass thoughts on Paris and ISIS. . .". No doubt a silly title but there was a point. The post simply asked some questions regarding ISIS. In a nutshell, the post asks whether ISIS is self-interested, and if it is, how or why would it initiate an attack on Paris.

That was what that post was about. The title, "Some dumbass thoughts. . . " however alludes to something else. For myself and probably for most, dumbass traces back to Beavis and Butthead. It was Butthead's refrain to the often nonsensical stuff coming out of Beavis' mouth. In hindsight, maybe Beavis was not always offering nonsense, but that is a whole different discussion. Going back to my post, and to borrow from Butthead, the title does point to something perhaps nonsensical.

There is, however, a disconnect here, as there is really nothing too nonsensical in my post. The post simply asks what is ISIS thinking, considering that such attacks as Paris will only reinforce and confirm the wests need to engage and destroy them - to eliminate the threat. I may not have the specifics right but in general it seems to be a legitimate question.

So why do I refer to my post as a collection of dumbass thoughts? I have already given above one hint regarding the specifics. I did not go into who the attackers were, where they in fact originated from, and what their actual relationship to ISIS was. So the neglect of details is a problem. That, however, is just part of it. The larger issue is our general willingness to espouse a position without full knowledge of the subject. I might have chosen to not go into such details, but one would hope that if you discuss a topic you have some understanding of it.

In this case, I know little about ISIS, or the events that took place in Paris. I know no more than the rest of us who sat stunned and saddened by what we saw on the TV and web during that time. That, however, is where dumbass thoughts come from - a willingness to talk about and make assertions about things we perhaps know little if anything about.

Today, it feels like, and this post might again be more of the same, but it does feel like we allow for, encourage and accept much that is really not known. The sources are easy to name. The web with all its dark corners and alleyways is of course loaded with all kinds of information, much true, a lot that is blatantly false, and good amount that is a mixed bag. On top of that, we have cable and talk radio, which focus on the political realm. And then you have of course the ongoing Presidential election and the resulting soundbites from Donald Trump and others. Another domain where you see this is regarding science, and pseudo-science. Just look at our discussions of global warming or vaccines.

So today, with the demise and shrinkage of local papers and print, we have turned to the web and to cable TV. With that, we do have a diversity of views and opinions-much of which I might term dumbass. The question becomes are these various views and positions dumbass? Are they knowledge? Do we or should we care?

So that is largely what I alluded to in using the term dumbass. That said, I do think the term does raise several issues regarding much of what we consider fact or knowledge, of how we treat or neglect the information available to us today. It is often joked that philosophy offers little to its students, but an appeal here to epistemology, the study of what it is to know, of what is required to claim knowledge, might just be appropriate. It could at the very least further broaden our understanding of what it is to be a dumbass.

To be continued. . .

Progress and Progressions - an Update

Awhile back I wrote a post, Progressions. . ., detailing three progressions that our world was experiencing. Actually that was back in 2011, not that long ago. Basically I pointed to three general trends and pointed to how culture and technology are intertwined and evolve based upon that relationship. Whether it is low-brow entertainment such as the Three Stooges, Jackass, and today Youtube, to recruiters moving from the New York Times to Monster and LinkedIn. Our culture and our technology do evolve, and there is an interaction between the two.

Another theme that I stressed or pushed upon in that post is that progressions are are not progress. And in the same breath they are more of an evolution. Which brings me to another topic that has haunted me for a long while: what is progress or Progress with a capital "P"?

Progress as I speak about it here is something expected in the world. It is a view of world as constantly improving. Whether you look at social issues, the economy, or technology there is a certain view that things are changing for the better and that is Progress. There is also the related and more limited version where only science and technology progress but not the social world. Here we continue to see the anticipated innovation in technology but not in regard to poverty and the economy.

Let me make one more point on what I mean by progress here. When I apply this concept I am not referring to a specific situation that happened to improve. Rather, I am saying it was inevitable that the specific situation and all situations will improve. In short there is or was a certain faith in Progress. It is Progress as the general improvement of life as the months and years unfold to which we are pointing to.

Going back to my original post, highlighting three cultural progressions, I doubt they involve this Progress with a capital "P" which I reference above. That said there is a certain progression that can be associated with the word Progress itself involving both "Progress with a capital P" and progress as a progression or evolution. It has a certain history or evolution.

To be continued. . .