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 conducted30 Analysis plan should be peer reviewed95 External review necessary34

Data Acquisition Percent Access to raw data by assessors very important69 Raw data made available to assessors often/always31 Access to data by peer reviewers very important59 Raw data made available to peer reviewers often/always 16 Inclusion/exclusion criteria should be used94 Standardized search protocols are used often/always24

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 origins82

Risk Management Factors Great Weight (%) Legal implications72 Political concerns66 Precautionary principle52 Environmental groups49 Science47 Media coverage43 Economic costs/benefits41 Industry28 How much weight do risk managers currently give to:

How much weight should risk managers give to: Risk Management Factors Great Weight (%) Science98 Economic costs/benefits67 Legal implications48 Industry20 Precautionary principle19 Environmental groups16 Political concerns8 Media coverage4

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 ?