Journal of Science Policy & Governance | Volume 17, Issue 01 | September 30, 2020

Policy Memo: ​Strengthening Transparency in Regulatory Science: The Environmental Protection Agency’s Proposal to Internally Regulating Science

R. Samuel Herron (1)*, Jonathan Klonowski (2)*, Cassandra Rios (2)*​
  1. University of Pittsburgh School of Medicine, Department of Pathology, Pittsburgh, PA
  2. University of Pittsburgh School of Medicine, Department of Developmental Biology, Pittsburgh, PA
*All authors contributed equally
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https://doi.org/10.38126/JSPG170113
Keywords: EPA, regulations, regulatory policy, peer-review, validation, transparency, executive branch
Executive Summary: Policy decisions by the Environmental Protection Agency (EPA) should be informed by consulting the most relevant and updated information. Accordingly, the quality of information used is an integral part of federal decision-making as it can add credibility to policy. In 2018, EPA proposed the “Strengthening Transparency in Regulatory Science” rule (EPA-STRS, updated March 2020) as an effort to assess the quality of studies used by EPA and increase transparency in policy-making decisions through conducting publicly accessible peer-reviews of all data and models. Herein we detail three arguments detailing differing perspectives on EPA-STRS and determine that, while the proposed rule purportedly seeks to strengthen the scientific underpinning of EPA policy, the current language risks the integrity of the agency’s policy-making process. EPA-STRS neither adequately details methodology with which independent validation would occur, nor delineates how valid exceptions to this rule would be identified in an unbiased manner. Furthermore, the implementation of this rule as currently written would allow for the politicization of EPA policymaking through abuse of the scientific study screening process. We propose that EPA amend EPA-STRS to reduce ambiguity, minimize biases, and address concerns related to independent research validation and peer review. 

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Samuel Herron is a graduate student at the University of Pittsburgh studying Cellular and Molecular Pathology. Sam holds a BS in Biology and Biochemistry from Virginia Polytechnic Institute and State University. He has served as the Treasurer of the Pitt Science Policy group for the last year, helping to organize events and manage funds for the group, and hopes to continue to serve the both group and the local Pittsburgh area for the remainder of his time in graduate school.
 
Jonathan F. Klonowski is a PhD graduate student researcher studying Congenital Heart Disease (CHD) at the University of Pittsburgh, School of Medicine. He employs a combination of computational and biological tools in order to investigate the role of ciliary signaling in CHD pathogenesis. Jonathan is the acting president of Pitt Science Policy group where he channels his passion for further integrating scientists at the local and national policy making process. Further to this, he is on the Diversity, Equity, and Inclusion Committee at the National Science Policy Network.
 
Cassandra Rios is a graduate student at the University of Pittsburgh pursing a PhD in Developmental Biology. She holds a B.S. in Genetics and Genomics from the University of California at Davis and was a Postbaccalaureate Fellow at the National Institutes of Health. Cassandra is a member of the Pitt Science Policy Group and plans to integrate her scientific background into a career in biotechnology-centered intellectual property law.
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