Editors' Column
Scientists Question Their Role in the Federal Regulatory Process In scientific circles as well as in t h e general population, questioning of the Federal regulatory process is taking place. Scientists are particularly questioning the scientific basis for regulations and are concerned also t h a t t h e regulations do not hamper their research efforts. Poorly designed regulations threaten to impede scientific progress without necessarily benefiting the public. It is incumbent upon us all to take note of what is happening and, as is appropriate in t h e democratic process, make input where we have special knowledge. This is t h e basis for Professor Laitinen's editorial last month, page 1409, and for the instigation of our new section entitled REGULATIONS, see page 1119 A, this issue. In New Hampshire in July the writer attended an Engineering Foundation Conference at which scientific representatives from industry, government, and universities discussed " T h e Scientific Basis for Government Regulations". T h e idea for this meeting was spawned a t last year's Gordon Research Conference on Analytical Chemistry. Cochaired by Ken Gardiner of the University of California, Riverside, a n d Myron Block of Block Engineering Co., t h e regulatory meeting had a proportionately large representation from the analytical chemistry community. Analytical chemists have special reasons to be concerned. Much of the activity in rule setting and enforcing depends upon measurements. Among the topics discussed by analytical chemists were sampling problems, analytical accuracy, validation of analytical methods, and " T h e Search for Zero". T h e latter presentation by Warren C r u m m e t t of Dow called attention to t h e unrealistic goal of seeking either zero impurities in any material or zero risks in any h u m a n activity. T h e Federal regulators were pretty well taken to task by the participants at this conference. However, balance was achieved in the last formal presentation by Ed Kimmelman of Du
Pont. In discussing "A Way Out of the Regulatory Mess," he offered many concrete suggestions on how to input effectively in the regulatory process. T h e interesting discussions t h a t took place a t the conference will be pulled together into a cohesive form for publication in t h e R E P O R T section of A N A L Y T I C A L C H E M I S T R Y early next
year. Somewhat disturbing, however, a t this conference and elsewhere were comments t h a t suggest a lack of recognition by many people t h a t there is no particular group of scientists with a corner on scientific truth. Likewise, there is no way to discuss regulations and their impact without taking into account political, social, and economic factors. Several times a t the conference some individual would suggest t h a t university scientists should speak up since the public no longer trusts industrial scientists, and everyone questions the government's credibility. Fortunately, this idea as a panacea was usually squashed by another participant who would remind the group t h a t all individuals have their own particular biases. There was definite agreement by participants at the conference that, although very messy, the democratic processes a t work in our society should eventually lead to acceptable solutions to regulatory problems. Of course, scientists do not know everything. The suggestion, however, t h a t we cease all regulatory activity until we have complete understanding of complex technical questions is not realistic. We will never know enough. T h e scientific process consists of gradually getting closer to the scientific truth. There is no final end to scientific inquiry. Decisions must therefore be made on t h e basis of partial truths. Scientists have an obligation to clarify realistically for the public the technical issues involved so t h a t the judgments made by the citizenry take into account the scientific facts to the ext e n t t h a t they are known. Whereas scientists may agree on a set of scientific facts supported by
pertinent data, they will often dispute the interpretation of these facts, based on nonscientific values. T h u s , it is particularly dangerous for any group of scientists to proclaim their ability to provide unbiased accurate interpretations of scientific data t h a t society should accept as T H E T R U T H . Fortunately, most scientists appreciate the difficulties involved in separating the interpretation of scientific d a t a from the economic and social issues. Recognition is given scientific expertise in a new decision from the E n vironmental Protection Agency (Chem. Eng. News, page 7, Aug. 14, 1978), which has modified its procedures in issuing discharge permits for conventional pollutants in its enforcement of the Clean Water Act. T h e new rules call for discharge permit hearings before a panel of agency experts knowledgeable of the scientific issues at hand. T h e agency hopes to minimize the adversary trial-type hearings of the past. According t o Costle, E P A administrator, " T h e thrust is to reduce the influence of lawyers and increase the influence of technical and scientific experts." T h e American Chemical Society, ever mindful of its Charter from Congress, is considering how best t o provide scientific information from its expert members to aid the regulatory processes. In J u n e ACS President Anna Harrison called a Conference on Mechanisms to Facilitate Society Participation in Regulatory Matters. Participants were from the Divisions, including two from Analytical Chemistry, members of ACS committees related to public affairs, ACS National Officers, headquarters staff, and guests from t h e regulatory agencies. T h e Conference came u p with a number of specific recommendations as to how the Society might help t h e regulatory process. These recommendations, which among other things call for technical help from the Divisions, are scheduled for discussion by Divisions and Committees at the ACS meeting in Miami Beach. Josephine M. Petruzzi
ANALYTICAL CHEMISTRY, VOL. 50, NO. 12, OCTOBER 1978 · 1143 A
