A scientist’s vallediictorv V
twin engines: its congressional mandates that require a complicated, resource-intensive. chemical-by-chemical approach to regulation, and its own tendency to apply scientific principles and knowledge in ever narrower, more technical, and arcane formulations. The result is aptly described by the adage, “paralysis by analysis.” I believe the SAB could alleviate this _ _ situation hy reviewing individual proAfter five pleasurable years, I am relin- grams not with regard to strict and quishing “Regulatory Focus” to new narrow number judging (e.g., “Is 0. I commentators. This is the ideal occa- mgiL the right level for a particular resion to take stock of a theme that has striction’?”), hut in a more basic Fashbeen continually. if not always explic- ion. Are the right goals being set? Are itly, explored during this period: the in- the right scientific, policy formulation, terface hetween science and public pol- and program evaluation questions being icy making, as reflected in regulatory asked’?Are the right measurements heactions. ing taken? Has sening control requireTo some extent. I am disappointed nients at the lowest possihle level (or and discouraged by what I see. True, the scientific equivalent of the lowest some of the mnre obvious problems detectable level) put us into a hox that sparked the national environmental where effective regulation has become movement of the 1960s and the ensuing unachievahle and therefore resulted in creation of EPA have k e n addressed virtually no regulation at all? with some degree of success. For exA few examples will illustrate. In the ample, the most blatant smokestack and air program, should the focus k on outfall pollution sources have come un- controlling overall emissions o r a der some measure of control. chemical-by-chemical approach’? But increasingly, the regulatory Would across-the-board reductions adestructure established by EPA’s enahling quately address the difficulties EPA has legislation and the agency’s own proc- experienced. for example. in issuing ess of implementing those laws have standards for hazardous air pollutants become unahle to perfnrm their func- (only eight NESHAPs have heen tion. There are a numher of likely rea- promulgated since 1970)’? Where is the sons: Political stalemates, institutional single-chemical approach justified’? barriers. and resource constraints have How can it best be implemented? Simicombined to make the environmental lar questions could he asked regarding regulatory systcm unresponsive. even water programs. unworkable. Regarding pesticides, what is the p a r ! Ifit is reduction of total adverse EPA’s use of science impact of pesticides on the environIn my view, EPA’s ineffective mar- ment. where should EPA direct its foshalling of its scientific resources is a cus? To increasing the restrictions on major culprit. In the area of scientific current pesticide products? What of the research alone. the agency’s efforts Consequences of substituting a similar have been flawed. My two most recent or related product for one judged unaccolumns summarized the recent report ceptahle under the present chemical-hyof EPA’s Science Advisory Board chemical system? Should more anen(SAR) that examined problems with the tion k paid to, and incentives be agency’s R&D program and rccom- developed to encourage. potentially mended solutions. Here. I am advocat- promising alternatives like the neing the extension of such an SAB re- glected Integrated Pest Management view to the programs administered hy approach! What consequences can reaEPA’s media oftices, that is. air, water sonahly he expected to attend such aland drinking water. solid and hazardous ternatives’? wastes. pesticides. and toxic suhA second major area that needs restances. thinking. I believe. is EPA’s use of risk In each of these areas, EPA has been assessnient as a decision-making tool. driven toward regulatory impasse by Here asain, an SAB review board can ~
0013936W8810922-1401$01 ,5010 i: 1988 American Chemical Society
be asked to address formulative policy questions rather than look narrowly at the adequacy of any single assessment of a specific chemical. Science can tell us a great deal ahout specific risk levels by calculating estimates of upper b u n d risk or the most likely risk. Rut what of the consequences-unintended and largely unevaluated-of the agency’s use of the most conservative estimate (the upper h a n d risk) over the past 10 years? Has it contrihuted to regulatory effectiveness or to delay and suhsequent inaction? Has science k e n used to look at the trees while the agency misses the forest?
Monitoring revisited It would k out of character for me not to heat a favorite drum one last time. Once again, I suggest that EPAs monitoring policies and systems he reexamined. Where such systems exist. are they measuring the right thingsnot .just individual pollutant levels-hut long-term trends, accumulationx and bin-system changes? Has the evergrowing requirement lor intensive monitoring of many chemicals at many sites in a small and perhaps unrepresentative section ofthe real world (e.g., RCRA monitoring at hazardous-waste disposal sites) led to a waste of financial and monitoring (lahoratory and personnel) resources? Are the masses of data generated in some instances of any real use-outside of a courtr(mm. perhapsin evaluating the health of a particular environment or a larger hiosystem’?Are the reliahle monitoring data hases that presently exist k i n g adequately incorporated into policy and regulatory determinations’? And so I close with more questions than answers; my audience may be laughing or crying or both. Akin, perhaps, to the old vaudevillian who seeks to leave ‘em laughing -or at least taking notice-I how nut with thanks to you, readers, for bearing with me over these years. Reporting on environmental policies to a technically sophisticated audience greatly interested in regulatory issues and actions has given me a unique vantage point and oppirtunity. It has k e n a wonderful experience. Richard M. Dowd, Ph.D., is president of R. M . Doud R Compuny, environmental rind science policy consultunt,~ in Washington. DC. Enuiron. Sci. Technol.. Vol 22, NO. 12,1988 1401
