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Revisiting ‘Best’ Science

April 7, 2014 | A version of this story appeared in Volume 92, Issue 14

March 10, page 32: Small amounts of cadmium, nickel, and lead have been detected not only in e-cigarette vapor but also in tobacco cigarette smoke.

The Headline Writer of a Government & Policy article claims that the Senate bill S. 1009, which reauthorizes the Toxic Substances Control Act requiring publicly available peer-reviewed science, “may be toxic” (C&EN, Dec. 2, 2013, page 24). The bill uses the term “best available science” (BAS) and relies heavily upon a process known as “weight of evidence.”

The author appears to misunderstand the nature of regulatory science in general and BAS in particular. The BAS concept seems to have been conceived upon the formation of the Institute for Regulatory Science (RSI) in spring 1985. Meanwhile, key leaders of RSI, myself included, have joined the newly established International Center for Regulatory Science (ICRS) at George Mason University. The definition of regulatory science as provided at the ICRS website is as follows: “Regulatory science is a scientific discipline consisting of the development and application of scientific methods, tools, approaches, and other relevant processes derived from various scientific disciplines used in regulatory and other policy decisions” (

The five principles of regulatory science, its three pillars constituting Metrics for Evaluation of Regulatory Science Information (MERSI) and other relevant information, can also be found on the ICRS website. BAS/MERSI includes peer review as a key element of the reliability of scientific claims. Similarly, transparency is one of its key principles, and experience indicates that key health and safety data can be separated from information that is of commercial interest to manufacturers.

The article claims that BAS as used in the Senate bill could force EPA to exclude industry data from safety assessment.

However, most regulatory science documents are routinely peer reviewed and not published in scientific journals. As shown on its website (, RSI has performed more than 300 peer reviews and scientific assessments for government agencies at federal, state, and local levels, including for Congress. Note that the RSI process was extensively reviewed and recommended by the National Academy of Sciences to be used by government agencies and was referenced in the peer review bulletin of the Office of Management & Budget. These functions are now transferred to ICRS, an organization willing to perform this important public service.

The American Chemical Society has access to many competent individuals within four divisions (environmental chemistry, medicinal chemistry, biological chemistry, and chemical toxicology). Wouldn’t it have been logical to contact key members of those divisions instead of contacting lawyers?

A. Alan Moghissi
Fairfax, Va.



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