The Social Benefits of Expedited Risk Assessments

Abstract

The present regulation of carcinogens is quite slow; hundreds of substances that have tested positive for carcinogenicity in animal bioassays have not been addressed by the U.S. regulatory system. This carries with it unappreciated social, economic, and public health costs. However, there are readily available expedited approximation procedures for assessing the potency of carcinogens whose use has substantial benefits that outweigh any costs from less science-intensive and less extensively documented assessments. These benefits can be seen by using a model to suggest the magnitude of social costs in regulating carcinogens by current conventional methods compared with expedited procedures for assessing the potency of known carcinogens. Two scenarios, one in accordance with current agency presumptions and one which assumes extreme unreliability in animal data and in the accuracy of potency assessments, compare conventional science-intensive and expedited procedures. On both, the total social costs of expedited procedures are lower than conventional procedures across a wide range of values assigned for individual mistakes of under regulation and over regulation. It appears better to evaluate a larger universe of known carcinogens somewhat less intensively for each substance than to evaluate a small proportion of that same universe very carefully and delay considering the rest.

Non-cognitive Values and Methodological Learning in the Decision-Oriented Sciences

“…In this sense, Cranor (1995Cranor ( , 1997Cranor ( , 1999Cranor ( , 2006 concludes that science is not normatively neutral in real-world applications that may have non epistemic (social or environmental) consequences. In other words, choosing to apply the aims and methodology of ''academic'' (and supposedly ''value-free'') science in the decision-making context is not a morally neutral decision.…”

“…And where cognitive values do not illuminate, social and ethical concerns do. Cranor (1995Cranor ( , 1997, in line with Douglas, considers that non-cognitive values may legitimately influence the choice of standards of evidence, as well as scientific methodology. A good example is his proposal for short-term tests (see above).…”

“…always imply normative commitments with respect to experimental design (Cranor 1997). False positives and false negatives as a result of methodological choices can have direct impacts on public health and the environment (Cranor 1995(Cranor , 2011Lemons, ShraderFrechette and Cranor 1997;Wandall 2004;Hansen et al 2007). As a consequence, Cranor (2006) proposes changes to scientific methodology, like the adoption of rapid, however less accurate scientific tests (so-called short-term tests).…”

Philosophical Foundations for Citizen Science

“…Similarly, when risk assessments are produced for the purposes of making regulatory or policy decisions, scientists have to balance the goal of producing reliable results against the goal of obtaining results in a timely fashion. In some cases, social costs could be minimized if scientists used less accurate assessment methods that generated results much more quickly (and thus facilitated faster regulatory decision making) but with a modest increase in false positives or false negatives (Cranor 1995). In the same way, when research is geared toward identifying potential public-health threats faced by communities, it might be appropriate to accept data or methods that are more prone to false positive errors in order to minimize the potential for false negatives (Barrett and Raffensperger 1999;Elliott 2014).…”

A normative analysis of nursing knowledge

“…In particular, some constitutive and epistemic values in pure theory can be adapted to a broader framework for applied science, in order to achieve different practice‐based goals. For instance, Cranor () argues that the social costs of adopting standard risk‐assessment procedures – currently very slow – for regulating carcinogens are greater than they would be if the regulating agencies provided less accurate but quicker methods. Thus, in this example from applied science, the non‐epistemic value associated with the rapidity of risk assessment seems to deeply influence some epistemic values related to the level of error of the quick but less accurate methodology.…”