If you are like me, and you are exposed to a lot of reporting from members of the Society of Environmental Journalists, then you are subject to a number of common themes, including:
- Obama’s Environmental Protection Agency was terrific and noble
- Trump’s EPA is terrible and does only what industry wants
- Science Advisory Panels are essential inputs of pure unadulterated science
- There’s no such thing as secret science at the EPA
The recent kerfuffle over chlorpyrifos demonstrates how these tropes can conflict.
Chlorpyrifos is a widely-used pesticide. Under the Federal Food, Drug, & Cosmetics Act, food containing pesticide residues is considered to be unsafe and therefore “adulterated,” and such food cannot be distributed in interstate commerce, unless the EPA has established a “tolerance” for the residue.
In September 2007, NRDC and Pesticide Action Network submitted to EPA a petition seeking revocation of all chlorpyrifos tolerances, which would take the pesticide off the market. The Obama administration sat on the petition for years, but ultimately proposed to grant it in November 2015.
Now, we start getting to the trope mix-ups. The Obama administration convened a series of science advisory panels to vet its regulatory science on chlorpyrifos. At the last of these meetings, which took place in mid-April 2016, “the SAP…appears to have rejected…the approach the EPA put forward in its proposed rule derived from the 2014 risk assessment,” as stated by the EPA. (See page 3). The panel never had an opportunity to vet the agency’s subsequent approach, because the clock ran out on the Obama administration.
And guess what the panel’s primary criticism was? It was secret science! The agency’s regulatory approach relied on a study from the Columbia Center for Children’s Environmental Health on pregnant women which reported an association between fetal cord blood levels of chlorpyrifos and neurodevelopmental outcomes. Here’s what the panel noted in its conclusions to the EPA:
Because many uncertainties cannot be clarified, the majority of the Panel does not have confidence that the Columbia Center for Children’s Environmental Health cord blood data on chlorpyrifos concentrations can accurately be used in quantitative risk assessment … A major source of uncertainty for the Panel was the lack of verification and replication of the analytical chemistry results … (See page 20)
When panelists broached the secret science, here’s how an EPA official (named “UNIDENTIFIED MALE” by the transcript) responded:
We don't have access to the raw data. We recently, well, we’ve been in conversations with Columbia to get that data. This morning I sent, based on an interview with a spokesperson from Mailman School of Public Health that said they would make the data available to us and sent a letter to the dean. But currently, we don’t have the raw data before us. (See page 48)
So there you have it: secret science exists. Moreover, this secret science was cited as a primary objection by the science advisory panel, which, according to several mainstream media reports, are paragons of science, so we know we can trust it.
Last month, the EPA administrator Scott Pruitt formally denied the NRDC/PANNA petition. Based on the above, his decision strikes me as reasonable. Of course, that’s not how it was reported. The New York Times headline reads: “A Strong Case Against a Pesticide Does Not Faze E.P.A. Under Trump.” The Los Angeles Times headline upped the ante with an accusation of impropriety: “EPA Chief Met with Dow Chemical CEO before Deciding Not To Ban Toxic Pesticide.” Unsurprisingly, neither article makes mention of either the science panel review or the missing raw data. After all, it stands to reason that confounding beliefs lead to cognitive dissonance for the modern progressive environmental reporter.