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

Abstract

: 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.