Deregulatory science: Chemical risk analysis in Trump’s EPA

Abstract

While critics cast the Trump administration as anti-science, requiring in response vigorous defense of science, analysis of the Trump EPA reveals instead a strategy to develop deregulatory science. In its first 3 years, the Trump EPA introduced and started to implement a variety of new frameworks to remake scientific risk analysis, changing how it assesses exposures, hazards and costs of chemical harms. The article focuses on EPA frameworks associated with the Clean Air Act, Strengthening Transparency in Regulatory Science rule and Toxic Substances Control Act. The new approaches compel the agency to ignore many pathways of exposure and pivotal studies of hazards, include dose-response models that treat pollution as healthful and change how costs and benefits are calculated. Yet it justifies these frameworks in terms of evidence-based decision-making, transparency and the separation of science from politics. According to its political appointees, the Trump EPA stands for scientific integrity, because it is promulgating evidence-based approaches in risk analysis that show regulation to be neither necessary nor appropriate. This is not just rhetoric but represents an effort to engage science to delegitimize environmental regulation. There is continuity between the Trump EPA and past efforts to use science to justify regulatory rollbacks: defending science by demarcating it from non-science is just as much a strategy for deregulation as it is for regulation. A key lesson is that contesting deregulation by declaring it anti-science reflects an impasse, as deregulatory approaches then also seek to take the mantle of science. The alternative to engaging in debate over demarcation is to make explicit the values and interests shaping practices of regulatory science.