by Richard Belzer

in Regulatory Economics, Regulatory Science

On July 11, 2008, EPA published for public comment an advanced notice of proposed rulemaking on the question whether, and if so, how, EPA should regulate carbon dioxide as a criteria air pollutant under the Clean Air Act. EPA simultaneously published a letter from Susan Dudley, Administrator of OMB's Office of Information and Regulatory Affairs, publicly distancing the Bush administration from EPA's proposal. Comments sent to EPA by other federal agencies also were made public.

This set of events may be unprecedented in the annals of federal regulatory poliicy. Today we begin a series providing a policy-neutral examination of the documents and the issues presented.

4 Jul 2008

Where Does Science End and Policy Begin?
Vitamin D

by Richard Belzer

in Regulatory Policy, Regulatory Science

Washington Post staff writer Rob Stein reports on a controversy over whether the federal government's recommendations for Vitamin D intake are adequate. The story illustrates the perils of delegating policy decisions to scientists. More...

21 Mar 2008

The Revised Ozone Standard:
Simple math and simple constitutional law

by Richard Belzer

in Regulatory Policy, Regulatory Science

The Washington Post's environment reporter says EPA has weakened the national ambient air quality quality standard for ozone. Given that the standard is going down, what does she mean? More...

12 Mar 2008

The Haze of Carbon Dioxide
According to the Washington Post, anyway

by Richard Belzer

in Regulatory Economics, Regulatory Policy, Regulatory Science

The Washington Post says carbon dioxide is visible to the naked eye. More...

19 Feb 2008

The Precautionary Principle in Action:
Is taking or not taking Vytorin 'precautionary'?

by Richard Belzer

in Regulatory Policy, Regulatory Science

A recent study raised doubt about the benefits of Vytorin, a patented combination of two anti-cholesterol drugs, ezetimibe and simvastatin. Some cardiologists say the study is sufficient evidence to stop prescribing it as widely; others disagree.

The decision whether to take Vytorin or its component drugs rests with patients, but they rely heavily on the advice of their doctors? How can patients makes sense of this debate? More...

1 Feb 2008

Objectivity in Risk Assessment:
The National Intelligence Estimate on Iran, Part 4

by Richard Belzer

in Regulatory Policy, Regulatory Science

The subject of the 2007 National Intelligence Estimate of Iran's nuclear weapons program is not the dominant subject of news reporting that it was when we first posted on it. However, a conventional narrative has developed to the effect that Iran's nuclear ambitions and developmental efforts are no longer a legitimate concern.

Today we hope to finish our series on this subject showing why this narrative is based on value-based preferences that various people and interest groups hold, and is not supported by the NIE itself.


More...

8 Jan 2008

Cancer Risks from Air Toxics:
Remarkably small, even when exaggerated

by Richard Belzer

in Regulatory Economics, Regulatory Science

The Los Angeles Times reports that cancer risks in Southern California from air toxics declined in 2006 by 17%. Any decline in cancer risk is good news. How good is it? More...

3 Jan 2008

Where to Have a Cardiac Arrest?
Answer: not in the hospital

by Richard Belzer

in Information Quality, People & Institutions, Regulatory Science

New York Times reporter Denise Grady previews a research report due to be published in today's New England Journal of Medicine that says many hospitals do not respond quickly enough to cardiac arrest. Leslie Saxon, who wrote an accompanying editorial, delivered the money quote: “You’re better off having your arrest at Nordstrom, where I’m standing right now, because there are 15 people around me.” More...

5 Dec 2007

Why Is Blood In Short Supply?
Anecdotal evidence of highly precautionary (but discretionary) donation policies

by Richard Belzer

in Regulatory Economics, Regulatory Policy, Regulatory Science

Recently Neutral Source managing editor Richard Belzer attempted to donate blood, but was declined. Although the story is anecdotal and not empirical, it suggests good reasons why this particular blood bank seems to always be in short supply. More...

4 Dec 2007

Objectivity in Risk Assessment:
National Intelligence Estimate of Iran's Nuclear Weapons Program

by Richard Belzer

in Regulatory Science

An unusual example of risk assessment appeared today in the news: the disclosure of an unclassified summary of the November National Intelligence Estimate (NIE) concerning Iran's nuclear weapons program. The document, which for obvious reasons is not transparent and reproducible, nevertheless is remarkably clear about the uncertainties which underlie its estimates. More...

19 Sep 2007

OMB's Principles for Risk Analysis:
OMB's initial response to the National Academy of Sciences

by Richard Belzer

in Regulatory Policy, Regulatory Science

Today the Office of Management and Budget issued a memorandum to agency heads directing them to adhere to certain principles of risk analysis. The memorandum is OMB's initial response to the report of a National Research Council panel that OMB asked to review a 2006 proposed bulletin on risk assessment. That report called the proposed text "fundamentally flawed" and gave seven recommendations, one of which was that it be withdrawn.

A fair reading of the new memorandum is that OMB followed this specific recommendation. More...

29 Jun 2007

Distinguishing Risk Assessment from Risk Management:
Telling them apart can be hard

by Richard Belzer

in Information Quality, Peer Review, Regulatory Science

Experts in risk analysis often distinguish between risk assessment and risk management. But sometimes they don't, and that can leave the public confused about the difference.

Today's example is trichloroethylene, commonly called TCE. More...

29 May 2007

Journal Peer Review and Objectivity:
The case of Avandia (rosiglitazone) and the New England Journal of Medicine

by Richard Belzer

in Information Quality, Regulatory Science

We've been a consistent supporter of high standards for information quality, especially for federal agencies that disseminate influential information in the support of regulatory objectives. We've also been consistently concerned about one particular aspect of the information quality and peer review guidelines issued by the Office of Management and Budget: the rebuttable presumption that scientific, technical, economic or statistical information published in peer reviewed journals satisfies the guidelines' standard for objectivity.

In the past week, the New England Journal of Medicine published online an article by Steven Nissen and Kathy Wolski claiming that Avandia, GlaxoSmithKilne's blockbuster drug for type 2 diabetes mellitus, "is associated with a significant increase in the risk of myocardial infarction [heart attack] and with an increase in the risk of death from cardiovascular causes that had borderline significance."

The Nissen & Wolski study has received enormous press attention. In today's Wall Street Journal former Food and Drug deputy commissioner Scott Gottlieb asserts that the NEJM has political motives for subjecting the study to inadequate peer review and publishing the study with excessive fanfare. Though not directed at federal information quality law and policy, Gottlieb's commentary suggests circumstances when OMB's rebuttable presumption of objectivity ought to be replaced with a rebuttable presumption of bias. More...

14 Mar 2007

Risk Management Under Uncertainty
Preventing terrorism

by Richard Belzer

in Regulatory Policy, Regulatory Science

The classic risk management problem consists of making decisions under uncertainty. Any decision, no matter how carefully considered and well informed, can err in either of two ways:

• By failing to prevent a risk from occurring
• By preventing a risk through the creation of a different risk

13 Mar 2007

Hype and Science
A new look at climate change policy and the science supporting it

by Richard Belzer

in Peer Review, Regulatory Policy, Regulatory Science

We've posted three times on different approaches to climate change, distinguishing the views of CO2 Pragmatists from CO2 Puritans. Whereas Pragmatists are open to market-based regulatory responses such as carbon taxes and tradable emission permits, Puritans are not. CO2 Hybrids are Pragmatists who are invested in technological remedies beyond what economic efficiency would achieve with correct market prices.

Most recently we implicitly defended Al Gore from criticism on both the right and left that he was insufficiently Puritan in his personal "carbon footprint," which appears to be rather large. We noted that the policy prescriptions on the web site for An Inconvenient Truth are consistent with CO2 Pragmatism. Thus, the strongest basis for criticism would arise if Gore did not actually behave as a CO2 Pragmatist by purchasing bona fide carbon offsets for the CO2 emissions he indirectly generates. We've found no evidence that he doesn't, and plenty of evidence that he can easily afford to do so.

In today's New York Times, William J. Broad identifies a different basis for criticism. The scientific claims about climate change in AIC are the subject of increasing controversy among climate change scientists.