References ( I ) Flick. W. A,; Schofield. C. L.; Websler. D. A. In Acid RainIFisherim: Johnson. R. E., Ed.;American Fisheries Society: Bethesda. MD, 1982; pp. 287-306. (2) Hasselrot. C. L.; Hullberg, H. Fisheries 1984, 9(1), 4-9. (3) Schofield. C. L.: Gloss, S.P;Josephson. D. “Extensive Evaluation of Lake Liming, Resloeking Strategies, and Fish Popdation Res onse in Acidic Lakes Following NcutraEzation by Liming”: Interim Progress Rcport NEC-86/18: U S . Fish and Wildlife Service, Eastern Energy and Land Use Team: Washington, DC. 1986. (4) Gloss, S . P: Schofield. C . L.; Sherman. R. E. “An Evaluation of New York State Lake Liming Data and the Application of
By Ellen Silbergeld
(5)
(6) (6) (7)
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Models from Scandinavian Lakes to Adirondack Lakes:” U.S. Fish and Wildlife Service, Eastern Energy and Land Use Team. Washington, DC, in press. Fraser. I. E.; Britt. D. L. “Liming of Acidified Waters: A Review of Methods and Effects on Aquatic Ecosystems”: Report 80/40.13; U.S. Fish and Wildlife Scrvice. Eastern Energy and Land Use Team, Washineton. Team. Washington. DC. DC, 1982. Schrieber. R. k K.;;Britt, D. L. Fisheries 1987. /2(3), 2-6. Adirondack Lakes Survey Cor ration. Vols. 1-15. $w York 1984-86 R~DOCIS. State Deparimeni of Environmental Conservation: Ray Brook. NY. Zurbuch. P E. Fisheries 1984, 9 0 ) . 4247.
(9) Gherini. S. A. et al. In n e Inregrated Loke-Watershed Acidificarion Srudy: Goldstein, R . A , ; Gherini. S. A,. Eds.; Electric Power Research Institute: Palo Alto. CA, 1984; Val. 4, pp. 7.1-7.47.
Howard A . Simonin is a senior aquatic biologist with the New York Department of Environmental Conservation. He has conducted research on the effect of acidic deposition and recently has evaluated New York i program of liming selected acidged waters. He is located at the Rome Field Station in Rome, NY
Science and the EPA: Voodoo toxicology
During the past eight years, EPA has had a mixed relationship with the scientific community. Its use of science has ranged from attempts to integrate stateof-the-art basic science into policy to proposals so inexplicable that they are charitably characterized as voodoo toxicology. During the first four years of the Reagan administration, actions were taken to deliberately purge EPA of its science base, and eminent members of the scientific-technical establishment outside the government were proscribed from appointment to agency advisory committees. More recently, EPA is relying increasingly on science to validate policy, particularly now that risk assessment has taken more precedence as a basis for policy and regulation. Through this process, however, remarkably inconsistent signals are being sent. For example, a series of highly controversial issue-specific decisions, such as the recent cancer risk management decisions on dioxin and arsenic, are being set in the context of explicit guidelines defining scientific ground rules that frequently contradict the content of the decisions themselves. Science has rescued EPA-and the country-from some of its worst attempts at “reform.” When, in 1982, Anne Burford accommodated George Bush3 Regulatory Reform Committee’s high priority identification of lead as a target for deregulation, the biomedical community fought against the idiocy of once again adding lead to gasoline. In less dramatic cases, scientists on National Research Council boards and committees have provided guidance that prevented EPA from adopting weakening policies on drinking water and other issues. More critically, there
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has been a forum for consensus development through the NRC that will outlive EPAs current inaction on radon and acid rain. The record of these outside scientific advisory committees is a strong endorsement for extending requirements for EPA to consult with the NRC on issues beyond air and water. Environmentalists are more than willing to trust this consultative process. It has been my experience that the deliberations of peer review have not caused undue delays in regulatory action, which are often rightly decried by Congress and my colleagues. However, the country cannot rely entirely on outside scientists to rescue EPA from its more egregious folly. Methods must be developed within the agency to internalize a primary allegiance to good science, to principles of health promotion and disease prevention, and above all to effective communication between EPA and the outside scientific world. Appointments of
W15936W8810922-1145$01.5010 0 1988 American Chemical Society
persons to the agency with scientific stature-like Bernard Goldstein and John Moore-are welcome signals of solidarity. But one of the greatest threats is EPA’s appalling mismanagement of intramural and extramural research. The Science Advisory Board of the agency has repeatedly criticized EPA’s lack of long-term research goals and the routine plundering of the Office of Research and Development resources by program offices. Extramural research is equally mismanaged: Many academic scientists have learned to distrust EPAs allegiance to the peer review process. Currently EPA is trying to gain s u p port for a new venture in long-term research-a novel quasi-governmental research institute. At the same time, however, the agency continues to work against allocation of Superfund monies to the National Institutes of Health for basic research on toxicology and environmental engineering. It is not clear that EPA truly accepts the integral role of research in improving decision making. Until these issues are resolved, and until EPA constrains its proposals from the voodoo of the dioxin “reassessment” series, it is hard for scientists to trust an institution with a record as unpredictable as EPA’s in supporting science and accepting its conclusions.
Ellen Silbergeld is a senior scientist with the Environmental Defense Fund. She received her Ph.D. in environmental engineering from Johns Hopkins Universiiy and sat for the past jive years on EPA’s Science Advisory Committee and has served on several committees of the National Research Council. Environ. Sci. Technoi., Vol. 22. No. 10, 1988 1145
