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January 23, 2020

The Use and Misuse of Transparency in Research: Science and Rulemaking at the Environmental Protection Agency

Author Affiliations
  • 1Gordon and Betty Moore Foundation, Palo Alto, California
  • 2Indiana University School of Public Health–Bloomington, Bloomington
JAMA. 2020;323(7):605-606. doi:10.1001/jama.2019.22026

Transparency in science is a laudable goal. By describing with sufficient clarity, detail, and completeness the methods they use, and by making available the raw data that underlie their analyses, scientists can help ensure the reproducibility of their results and thus increase the trustworthiness of their findings and conclusions. At the same time, transparency is not in and of itself a definitive standard for the usefulness of science in policy making.

A proposed rule at the Environmental Protection Agency (EPA), “Strengthening Transparency in Regulatory Science,”1 goes too far in barring from pivotal consideration in regulations any scientific study that does not have all data and analytic models made publicly available, unless special dispensations are granted. In particular, epidemiological and clinical studies that are designed to protect the confidentiality of personal health information may be highly germane to establishing environmental standards yet ethically barred from making all data publicly available. Other studies may rely on proprietary information, and their main findings may have been replicated in independent, proprietary studies, yet under the proposed rule, such studies similarly could not be relied on as a basis for regulation. The proposed rule provoked hundreds of thousands of comments and also was the subject of a recent congressional hearing.2

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