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

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 do risk managers currently give to:

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 corruptedby 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 riskswhen testable risks are scientifically possible

• Regulations based on exposure reductionsbalanced 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 ?