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SciPoll 551: USEPA's Proposed Changes to TSCA Risk Evaluation Framework Rule
The codified definitions for "best available science" and "weight of scientific evidence" should be removed
Results
(109 Answers)
Answer Explanations
- Agreeuser-153519Both terms should be removed because it would avoid any discussion on the strict definition of those terms instead of the possible hazard of some chemicals.
- Disagreeuser-125195Given the uncertainty of knowledge and how laws are written regulators, informed by assessments of risk assessors, need to consider "best available science" and the "weight of evidence" in totality. That said, I note that codified definitions can always be improved and should be reevaluated periodically and refined if/when necessary
- Disagreeuser-841110An emphasis on scientific rigor should be maintained.
- DisagreeSonne72Always needed. But it should always be done this way but always good to emphasize though it could be removed.
- DisagreeSciPinion Adminsome definition is needed because that is what scientists strive for implicitly; not saying that the current definition is god, but simply that it is needed, should not be removed and replaced with a void open to interpretation. more precision is criteria is needed, not less.
- Agreeuser-523578Scientific evidence evolves.
- Agreeuser-911600Speed up production
- No opinionuser-445218I am not familiar with the definitions
- Disagreeuser-568782I opt in a possibility for updating according to the evolution of the technology or ethical considerations (industry influence for instance) , instead to remove the codified definitions for "Best available science"...
- Disagreeuser-153764EPA should retain the phrase weight of evidence
- No opinionuser-997228The removal of codified definitions for terms like "best available science" and "weight of scientific evidence" from regulatory frameworks can have both merits and demerits.
Arguments in favor of removal:- Flexibility: Eliminating specific definitions can provide more flexibility in interpreting these terms, allowing regulatory agencies to adapt to evolving scientific advancements and methods.
- Reduced Rigidity: Removing codified definitions may prevent potential constraints that rigid definitions can impose on scientific advancements and new methodologies.
- Avoiding Obsolescence: Definitions can become outdated as scientific knowledge progresses. Eliminating them might prevent regulations from becoming obsolete or inadequate over time.
Arguments against removal:- Ambiguity: The absence of clear definitions can lead to ambiguity and differing interpretations, potentially resulting in inconsistency in applying these scientific principles across different regulatory decisions.
- Lack of Guidance: Clear definitions offer guidance to regulatory agencies, industries, and stakeholders, ensuring a standardized understanding of scientific standards and expectations.
- Potential for Misinterpretation: Without explicit definitions, there's a risk of misinterpretation or misuse of scientific principles, leading to less effective decision-making in regulatory processes.
- Agreeuser-678105"weight of scientific evidence" has a psychological component that depends on the evaluator
- Agreeuser-553839The removal will ensure that the ordinary person can also access the nuances of best available science. We should not do science only for scientists but must also take into consideration the common masses. Educating the common people is an excellent idea that will percolate down through the ladder improving the social and societal structure making the community more robust.
- Disagreeuser-754769Drugs should be defined scientifically and scientific evidence is important.
- Agreeuser-114825Subjective positions
- Agreeuser-931808Leads to ambiguity
- Disagreeuser-673903These definitions need to be standardized. "Weight of evidence" is very important and highly used. "Best available science" is a moving target currently with the use of computational methods and in silico. Risk assessment agencies may not have the best tools or most qualified persons to perform best available science. This definition is rather subjective, where weight of evidence is more solid.
- Disagreeuser-653570Definitions for those terms will help to clarify what EPA considers to be the "best available science" or "weight of evidence" rather than leaving it to the reader to define however they wish. It would be better if EPA was more precise.
- Disagreeuser-521436These are concepts well rooted in risk assessment; and there are ongoing discussions at regulatory levels to clarify the criteria to establish "best available science" and "weight of scientific evidence."
- Disagreeuser-574398Having some standard /goal to guide both information and conclusions is more helpful than not.
- Disagreeuser-378118Any statement during evaluation of risks, should be backed up by evidence - to go beyond feelings or biases.
- Disagreeuser-414626Best available means that science that is not at the top of the heap is not considered. In WoSE, all studies are considered and their quality determines the weight. Sometimes the second best and third best studies can provide useful information.
- Disagreeuser-411596The phrases "best available science" and "weight of scientific evidence" are commonly used in scientific and regulatory contexts to describe the quality and reliability of scientific information. These terms are essential for ensuring that decisions, particularly in areas like public health and environmental regulation, are based on sound scientific principles. Removing these codified definitions may have significant consequences for the integrity and transparency of decision-making processes.
- Agreeuser-691039Especialy tox science is heavily hunting for money. Many reports are due to insufficiëntie methodologie and not enough scrutinizing results. Result a flutter of publications aimed at generating concern ultimatly hunting for funding. Like we have seen in nano tox publicatons
- Agreeuser-499245These terms are completely subjective and can be used to manipulate the result of the risk assessment.
- Disagreeuser-697562Best available science encompasses not only the weight of scientific evidence but also the quality of available scientific evidences.
- Disagreeuser-175854
Removing these definitions could lead to ambiguity and inconsistency in how scientific evidence is interpreted and applied in risk evaluations, potentially undermining the effectiveness and credibility of the process.