Regulatory Buffers

In response to “Toxic Chemical Rules in Limbo” by Cheryl Hogue, it should be pointed out that White House offices, as part of their duties, review regulatory policies and provide a means for the public to air their concerns before the policies are put into action (C&EN, Jan. 7, page 16).

It has been my experience that decisions by regulatory agencies, despite the best efforts of everyone involved, are occasionally made on the basis of irrelevant science or unsubstantiated speculations as to the mechanisms of chemical reactions. Most often, problems arise from the extrapolation of results of in vitro studies to real-life situations. Occasionally, speculations are treated as confirmed facts.

Regulatory decision making is subject to human frailty, and the practice of science, although it is the best method we have for making decisions, is not infallible. The White House Offices of Information & Regulatory Affairs; of Science & Technology Policy; and most important, of Management & Budget provide a valuable buffer against potentially mistaken policies and unintended consequences of the actions of regulatory agencies.

Jeffrey R. Ellis
Weston, Fla.