CONSIDERATIONS ON THE SURVEY
OF THE
CENTER FOR MEDIA AND PUBLIC AFFAIRS
G.B.Gori 12/6/2013
Problem Formulation/Analysis Plans
Percent
Problem formulation/analysis plan very
important
68
Problem formulation always/often conducted
30
Analysis plan should be peer reviewed
95
External review necessary
34
Data Acquisition
Percent
Access to raw data by assessors very important
69
Raw data made available to assessors often/always
31
Access to data by peer reviewers very important
59
Raw data made available to peer reviewers
often/always
16
Inclusion/exclusion criteria should be used
94
Standardized search protocols are used often/always
24
Data Evaluation
Percent
Goal of using all relevant and reliable studies is met
always/often
44
Consistent/transparent criteria are used to evaluate studies
always/often
24
Same criteria should be used to evaluate studies of all origins
82
How much weight do risk managers currently give to:
Risk Management Factors
Great Weight (%)
Legal implications
72
Political concerns
66
Precautionary principle
52
Environmental groups
49
Science
47
Media coverage
43
Economic costs/benefits
41
Industry
28
How much weight should risk managers give to:
Risk Management Factors
Great Weight (%)
Science
98
Economic costs/benefits
67
Legal implications
48
Industry
20
Precautionary principle
19
Environmental groups
16
Political concerns
8
Media coverage
4
WHY THE DISCONNECT BETWEEN WHAT IS DONE
AND WHAT SHOULD BE DONE?
Because we do not keep in mind certain
fundamental premises:
What is that legal/government framework
that allows the imposition of regulation
And consequently:
What the science framework should be
THE IMPORTANCE OF CLEAR PREMISES
 We do not wish to be ruled by arbitrary governments
 We expect regulations to be rational and factually justified
 Health and safety regulations depend on risk assessment
 Risks can be factually assessed only on scientific grounds
 Risks cannot be always assessed on scientific grounds
 Reducing exposures below thresholds reduces risks
 Absent objective risk assessments, rational regulations
balance reduced exposures and economic advantages
SCIENCE AND OBJECTIVE RISK ASSESSMENT
• Raw data that are relevant to humans
• Raw data measured with a testable small margin of error
• Raw data that are authentic and not corrupted
by interferences extraneous to the test at hand
• Factual correction of extraneous interferences
• Robust statistic significance
• Results reproducible by different investigators
• Counterfactual evidence
RISK SCIENCE DOES NOT ADMIT
• Raw data irrelevant to humans
• Default assumption applied to raw data irrelevant to humans
• Safety factors applied to raw data irrelevant to humans
• Default mode of action assumptions applied to the statistics
of risk assessment
EXPECTED MODES OF RATIONAL REGULATION
• Regulations based on objective risks
when testable risks are scientifically possible
• Regulations based on exposure reductions
balanced by considerations of economic utility,
when testable risks cannot be obtained
REGULATION CANNOT IGNORE ETHICAL DEMANDS
• Regulation interferes with trillions of dollars of economic
activity
• Regulation interferes with the behavior and anxieties of
humanity
• Regulation raises massive fines on those it considers as
transgressors
• Regulation can jail on its terms those it considers as
transgressors
COULD THIS BE DONE ON THE BASIS OF ARBITRARY ASSUMPTIONS ?