the Fox Bought a Ticket into the Chicken Coop?
The National Institute of Environmental Health Sciences has signed a Memorandum of Agreement with the chemical industry trade association, American Chemistry Council, "to improve testing chemicals for potential human developmental and reproductive effects," according to a NIEHS press release dated 26 July.
ACC will provide $1 million and NIEHS $3 million to a $4 million fund that will support research "on the mechanisms of action of potential developmental toxicants using state-of-the-art tools, including genomics and genetic animal models."
At first blush this sounds great: more money for critical research that will help build scientific understanding of health risks caused by chemical contamination. A closer consideration of the arrangement, however, reveals that its main effect may instead be to undermine the independence and integrity of NIEHS science.
A key flaw it the arrangement is that it places ACC representatives on a panel that will screen research to be funded. According to the press release from NIEHS:
This implies that industry representatives will be directly involved in the selection of proposals to be forwarded to the peer review panels assessing scientific merit.
Note below about clarification from NIEHS dated 31 July 2001.
Predecessors of the ACC have a documented track record of repressing scientific data that threatened their products. There is no assurance that the ACC has changed its patterns of behavior. In fact, in a public debate following airing of Bill Moyers' "Trade Secrets" in March 2001, an ACC spokesperson continued to misrepresent the facts about what was known and not known about chemical threats to health.
While the arrangement calls for peer review of scientific proposals and that "applications ranked of the highest scientific merit will be offered funding," if the selection process has already screened out studies industry doesn't want done, or scientists industry doesn't want involved, then the procees is fundamentally flawed.
If industry-based scientists are also involved in the peer review process, then the program is in double jeopardy. Anyone who has been involved in peer review of proposals know how subtle lobbying can eliminate the most important research under consideration.
This MOU is a really good deal for the ACC and a terrible arrangement for independent science. $3 million that NIEHS had to conduct independent research will now be influenced by the priorities of the ACC.
There is a second key flaw in this MOU. Not only does this give ACC inappropriate influence over the direction of research, it also provides them with early warnings on troubling findings in ways that may discourage scientists concerned about the integrity of their work from applying for funding.
To apply for funding from this program requires that applicants explicitly agree that their proposals can be shared with the ACC. According a web-posted description of the program:
Scientists regularly put preliminary results into their research proposals. This arrangements creates a real risk that these preliminary results will now flow directly to the ACC and thence to lawyers and PR flacks preparing defences for their products. It may even make it less likely that scientists with challenging findings will seek NIEHS funding, because of fears of abuse of information by ACC.
Participation also requires attending an annual meeting sponsored by ACC and NIEHS (from the web-posted description):
So not only will ACC and thence ACC member companies learn about research proposals as they are submitted, they will get periodic updates on the progress of research. This puts the fox directly into the chicken coop.
A recent Government Accounting Office report (link to .pdf file) found that industry had too much influence on EPA advisory board decisions. This MOU now threatens the NIEHS with a similar challenge.
Industry should fund this research but the selection of research questions and researchers should be completely insulated from industry biases.
In the NIEHS press release, ACC President Fred Webber commented: "We expect this is the beginning of a long -- and mutually beneficial -- relationship with NIEHS and other federal agencies that also seek synergistic collaborations with industry."
Following significant public interest in the announcement of the NIEHS-ACC agreement, NIEHS issued a clarification:
This clarification offers a welcome perspective on the NIH peer review process. It does nothing, however, to resolve concerns about inappropriate intrusion of the American Chemistry Council into the conduct of NIEHS science. The fox remains in the chicken coop.