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®: CRE Regulatory Action of the Week

The National Academies’ Report on Risk Assessment: Strong on Policy, Weak on Science

Imagine the outcry if the IPCC stated that its assessment of climate change was influenced by policy views. But that is exactly what the Academies' recent "Scientific Review" of the draft OMB risk assessment guidance advocates.

Congress has told OMB in the Data Quality Act to ensure that risk assessments are objective, a comparable directive is contained in the Academies' mission which states their internal “ review process is structured to ensure that each report is …. objective.” If a report is to be objective, it can not contain biases inherent in policy judgments.

Notwithstanding the existence of a statutory directive reinforced by its own mission statement, the Academies' not only concluded that they are "troubled" (p. 63) by OMB's reliance on the legislative mandate contained in the DQA but they also concluded that policy views should play a critical role in risk assessments: "[The OMB bulletin] ignores without explanation the critical role that policy judgments play in risk assessments." (p. 15).

The Academies strongly support OMB's peer review guidance, and that guidance requires that peer review be limited to the science. Why in one instance does the Academies’ oppose the co-mingling of science and policy and in the other support it?

One explanation is that Academies’ reviewers of the OMB risk assessment guidelines wanted to maintain consistency with previous NRC reports which allow the co-mingling of science and policy; to accomplish this objective, the NAS had to first disavow the DQA to destroy the “objectivity” requirement and second had to argue that agency scientists are in a better position to make policy decisions than are duly elected officials.

  • Read the Academies' criticism of OMB Risk Assessment Guidelines
  • Read the Academies' support for OMB Peer Review Guidelines
  • Read Relevant Sections of OMB Peer Guidelines