• 28 NOV 08
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    #995: Bushian Science Policy Rules The Day: Risk Assessment in the EC

    One would hope that by now the world has learned the very hard lesson that the George W. Bush administration and its policies are not to be trusted, to say the very least. This should be especially so in Europe but it seems that when it comes to regulatory science, the Bush administration”s policy makers, both former and current, are successfully dictating how European regulators should protect the health of their citizens. Case in point is the recent EC conference in Brussels, titled: “International Conference on Risk Assessment”. A major reason for this conference was to explore the use of risk assessment in regulatory decision making. See:


    In Session 1, titled “Setting the scene”, the first presentation was by John D. Graham from the Indiana University, School of Public and Environmental Affairs. Graham”s presentation was titled “Risk Assessment for regulatory decision making” See:

    Before Graham was rebadged as a respected academic he was the politically appointed director of the White House Office and Management and Budget (OMB) in the Bush Administration. In this role he has been referred to as the “Regulatory Czar” where he carried out the administration”s policy to roll-back environmental regulations to benefit of corporate polluters. Previously Grahan was founder and director of the Harvard Center for Risk Analysis (HCRA) which was funded by a large number of corporate industry polluters to develop a technique of risk assessment that would protect their interests and inhibit regulation of their activities. For a background on Graham see:
    1) “Safeguards At Risk: John Graham and Corporate America’s Back Door to the Bush White House” Link:

    2) “Harvard Center for Risk Analysis and Big Tobacco”: Link:

    It is interesting to note that Graham has also worked with Michael Repacholi in developing the WHO”S International EMF Project”s approach to EMF risk assessment. This is seen in Graham”s 1998 Key Note presentation: “Making Sense of Risk: An Agenda for Congress” that was delivered at the WHO “EMF Risk Perception and Communication International Seminar”, held in Ottawa, Ontario, Canada, August 31 to September 1, 1998. His presentation was the blueprint for the later Bush administration”s science regulatory policy that gutted so much of America”s hard-won environmental regulations.

    Another presenter in Session1 of the 2008 EC risk conference was Graham”s former colleague Nancy Beck from the OMB who gave a rundown on the Bush administration”s regulatory risk assessment process in the U.S.

    This was later followed by a Key Note presentation in the 2nd Session by George Gray, the Bush-appointed chief of the U.S. EPA’s Office of Research and Development. Gray formerly was from Graham”s Harvard Center for Risk Analysis, where he co-wrote numerous academic articles on risk assessment with Graham. Gray”s presentation was titled: “Overview of activities to identify and assess new and emerging issues and challenges related to chemical, physical, and biological agents”.

    In his presentation at the 2008 EC risk conference Graham claimed that the biggest myth about risk assessment is that “it is an anti-regulatory tool that undermines protection of the public.” Read the following excerpt from “Safeguards At Risk: John Graham and Corporate America’s Back Door to the Bush White House” and consider the truth or otherwise of Graham”s claim.

    This rot is now spreading to the EC as well””.

    Don Maisch


    From “Safeguards At Risk” (2001):

    “News reports published the week of March 5, 2001 indicate that John Graham, founding director of the Harvard Center for Risk Analysis (HCRA), was nominated by President Bush for a position as the new regulatory czar in the White House Office and Management and Budget (OMB). Most Americans have never heard of John Graham, but if the U.S. Senate approves, he will be in a position to wield enormous power, and to undercut public health, safety and environmental protections for years to come.

    Graham would head the Office of Information and Regulatory Affairs (OIRA), which vets any significant or controversial regulation before it can be implemented. Over the past decade, Graham has been a prominent figure in the fight to halt or delay the issuance of protective safeguards by federal regulatory agencies, working with and receiving funds for his activities from dozens of major corporations. At OMB, he would be able to impose his will on the agencies, perhaps even on behalf of his former industry supporters, by blocking the development of standards and eviscerating the government’s regulatory framework.

    There are three major problems with Graham’s potential rise to power within OMB. First, Graham is certain to favor the regulated industries that have handsomely supported his Center. Graham has amply demonstrated his willingness to ignore, or gloss over, his own conflicts of interest. This report shows that Graham’s Center has accepted money from chemical companies, auto manufacturers, energy and oil interests, and other industries hostile to regulation. Yet, invoking the 1 prestige of Harvard University, he has consistently testified before Congress and been widely quoted by the media as though he is a neutral academic “expert,” with no disclosure of the sources of his Center’s funding in the article or testimony.2

    As discussed in Part One: Who Is John Graham?, Graham’s research has been used to lend a “scientific” veneer to corporate efforts to roll back safety and environmental standards, and to push for a top-down reorganization of the government’s basic regulatory scheme. Graham’s Center is funded by more than 100 large corporations and trade associations, including such known environmental offenders as Dow, 3M, DuPont, Monsanto and Exxon, in addition to the Chlorine Chemistry Council, the American Automobile Manufacturers Association, the American Petroleum Institute, and the Chemical Manufacturers Association, now called the American Chemistry Council. High-ranking 3 corporate officers from Oxford Oil, the National Association of Manufacturers, Eastman Chemical, Tenneco Inc., CK Witco Corp., and Novartis Corp. sit on the Center’s Executive Board. The HCRA 4 Advisory Council includes executives from DuPont and the Grocery Manufacturers Association, and the chief attorney for environmental affairs at Exxon Chemical Americas.5

    Second, Graham’s methodology appears to be informed more by the wishes of his corporate backers than by anything recognizable as “science.” Although he often calls himself a “scientist,” Graham’s field of risk analysis is a discipline within the field of public policy, and he does not in fact hold any degrees in the hard science disciplines that often form the basis for regulatory policy. As this 6 report demonstrates, Graham’s research conclusions are frequently marred by his inflation of industry costs and underestimations of the public benefits of safeguards. The practice of cost-benefit analysis also omits or downplays ethical and moral factors such as justice, consent and equity, and inappropriately discounts the value of human life and the environment.

    Graham’s Center, acting under the auspices of the Harvard School of Public Health, churns out research in support of industries that have a keen financial interest in seeing health and environmental safeguards dismantled or delayed. In Part II, we examine three case studies of his work and show that:

    * Graham solicited financial contributions from tobacco giant Philip Morris in the early 1990s and invited the company’s public relations officials to review a draft chapter of Graham’s book on the subject of second-hand smoke. Internal company memos show that Big Tobacco relied on Graham as part of its strategy to generally discredit the Environmental Protection Agency (EPA) and to undermine an EPA risk assessment of the cancer-causing effects of second-hand smoke.

    * In July 2000, as many cities and states were considering outlawing the use of cell phones while driving, Graham published a study (funded by AT&T Wireless Communications for $300,000) assessing the risks. The study came out against a ban on using cellular phones while driving, concluding that such a ban would be more costly than air bags and that there was “not enough reliable information on which to base reasonable policy.” As Tom and Ray Magliozzi, hosts of Car Talk from National Public Radio put it in response to a similar study by Robert Hahn, Graham’s intellectual and political ally at the American Enterprise Institute-Brookings Joint Center for Regulatory Studies, “This seems to us to be a clear case of cost/benefit analysis run amok.”7

    * Graham has wildly distorted the facts when advocating industry positions in the media. For example, amid fierce controversy over defectively designed air bags in 1997, he wrongly told the Associated Press that “most” of the 38 children killed by air bags had been decapitated. The same year, he appeared on ABC’s Good Morning America to report that a Harvard Center for Risk Analysis study had found that the “cost” of passenger side air bags was $399,000 for each year of life saved. After harsh criticism, the study was peer reviewed. When it was finally published in the Journal of the American Medical Association, Graham had flip-flopped — revising that estimate down to $61,000 per life year saved, and concluding that air bags were, in fact, a worthwhile and life-saving investment.

    The third reason Graham is unfit to serve at OMB is because of his long-standing strategic and research services to an entire network of anti-regulatory corporate interests, who would expect to call upon his sympathy. Part III: Science for Sale, explains six of Graham’s public relations techniques, showing how an anti-regulation political strategy is packaged as “necessary” information about human health and the environment.

    For example, Graham was a member of the EPA Science Advisory Board that reviewed the agency’s risk assessment on dioxin, an industrial contaminant, in 1994 and 2000. In June 2000, the 8 EPA announced a draft of its study, which showed that exposure to the level of dioxin currently in our environment causes an increase in the average American’s lifetime cancer risk to as high as 1 in 100. The EPA’s reassessment also found that dioxin, even at very low levels of exposure, is linked to infertility, immune system damage and learning disabilities.9.

    But rather than acknowledging that dioxin poses an additional threat to human health, in his comments to the media Graham misleadingly downplayed the risk by comparing the EPA’s findings to other types of risks, such as the risk of dying in a car crash. When compared with these risks, 10 Graham suggested, the risk posed by dioxin appears “normal.”

    The National Public Radio report containing Graham’s comments failed to mention his position on the Science Advisory Board and failed to disclose that his Center is supported by money from 48 different dioxin producers, including incinerator companies, pulp and paper companies, cement kilns, copper smelters, PVC manufacturers, PCB producers and the petroleum industry.11

    Graham’s tight connections to the chemical industry have also influenced his legislative work. Graham spoke at a panel discussion held around 1994 at the Chemical Industry Institute of Toxicology (CIIT) alongside executives from Eastman Kodak, the American Industrial Health Council, Air Products and Chemicals, E.I. DuPont de Nemours, and the Chemical Manufacturers Association (now called the American Chemistry Council). 12

    The topic was a Congressional bill that would have imposed rigid cost-benefit criteria on federal regulatory agencies in order to deter the development of new public health, safety and environmental protections. Graham commented on the relationship between the rollback “reform” bill and the chlorine’s industry’s support for institutions such as CIIT: “Those of us advocating reform could not be as effective as we have been in advocating the role of science in risk assessment if we did not have the underlying data and methodologies that were created here at CIIT,” he said. All of the 13 trade associations and companies listed above are also funders of Graham’s Center.14

    Graham has been a critical player in a decade-long, multi-industry campaign to discredit federal agencies and to block the regulatory process, and his use of the Harvard name helped to legitimize these attempts to rewrite the rules on public health and environmental issues. As this report shows, debates over the safety of pesticides, injury prevention, pollution, second-hand smoke, toxic chemicals and contamination of our food and water have all been victims of these efforts. If Graham goes to the 15 OMB, he could serve as the back-door conduit for a new corporate assault on public and environmental health.”

    Further reading on John Graham and OMB:

    OMB Expands Influence Over Scientific Decisions

    Integrity in Science Watch May 15, 2006

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