comment for RoC procedures meeting

[ttweed@wildrockies.org (Tony Tweedale)]

Please accept the following comment for discussion at NTP's 15 Sept. '99
meeting that will consider the review process and evaluation criteria for
listings in the 8th & 9th iterations of the Report on Carcinogen's (RoC).
The addendum to the July '99 _NTP Update_ newsletter summarizes such
comment developed during the listing process for these RoCs, including:

"* Expand the use of unpublished data;"

In all instances, NTP procedures should work to ensure data used is as
valid as possible and does not come from parties who have massive economic
interests in having their product or byproduct declared safe.  Just because
a party has the money to do many tests and the government, representing the
public trust, has little, does not mean NTP should use the data from the
party with the humongous conflict of interests.  Use of *scientifically
valid* unpublished data can be of great benefit, so long as, e.g., if it
comes from the toxin's producer it is independently replicated or
completely disagregate and each element is verified to be scientifically
valid.


"* Involve experts from potentially affected industries in a more iterative
manner earlier in the review process;"

The RoC process (and the NTP generally) should strive to ACHIEVE THE EXACT
OPPOSITE!  It is incompetent to think that because a party has any interest
they should necessarily help determine public trust decisions regarding
that interest.  Here the implication seems to be that a producer's massive
private, amoral economic interest in its toxin should give it a strong
voice in the public trust decision!

In science and elsewhere it is often stated that: "The *appearance* of a
conflict of interests should be avoided."  Logic shows that an economic
conflict of interests with the scientific method actually exists *as soon
as* a person who becomes involved in regulation of that agent is
subservient to, receives compensation (e.g. salary, pensions, stock
holdings, contracts) from, or even has certain non-economic attachments
with, a party with private economic interests in the potential carcinogen
or otherwise toxic agent involved.  It is not a deliberate conflicted act,
but rather simply being in the conflicted situation that determines a
conflict of interests.  Therefore the strict scientific and moral standard
is that no one should be trusted to do the right thing; rather such
situations should be avoided.

For example, I see the pending decision on the listing of 2,3,7,8-TCDD
(TCDD) as a known human carcinogen in the 9th RoC was unanimously approved
for further action towards final listing by both NTP RoC Working Groups,
which I believe are made up solely of government officials and experts;
whereas the next NTP group working on the listing (the NTP Board of
Scientific Counselors' RoC Subcommittee), which voted 7-5 against it being
listed, is the NTP's *external* peer review group.  Shortly thereafter a
new, critical piece of epidemeologic evidence was published that added
significantly to the weight of the evidence that TCDD is a multi-organ,
multi-species  human carcinogen.

External peer review is one of the most critical elements of the scientific
method, and I am not suggesting 7 members or even 1 member reviewing the
proposed listing voted against it because they represented economic
interests who produce or release TCDD.  I do not know who this
subcommittee's members are.  I am only noting the large vote difference
between public trust agents (without peivate interests) and the BoC
subcommittee's presumably varied memebership.  Decision-makers in the
critical public trust who have economic, even certain emotional or mental
ties to producers who have *every interest* in making "look, it's safe"
declarations, means that their decision-making on matters of public health
cannot be trusted.  Essentially it's a matter of public vs. private
interests and motives, but it also violates the essence of the scientific
method, which demands all relevant factors (not just data) in a question of
science be open, competent criticism.  Only out of this severe fire can
valid scientific decisions in the public trust be forged.

Billions of workers and others have been poisoned, and certainly thousands
have died, because of phenomenal undue industry involvement in the ACGIH,
which sets what their lawyers call "recommended" ambient occupational
exposure safe levels (TLVs) to toxins, but that in fact ACGIH industry
members have successfully lobbied to have adopted as law by countless
agencies, including the US government and other countries (the TLV process
continues to be secretive and heavily influenced by the toxins' producers.
At least in the past, TLVs were set simply on current factory floor levels
or what the chemical's producer believed it could afford).

I dearly hope the NTP will throw this suggestion into its wastebasket
without further consideration, and endeavor to isolate its critical mission
and its work from private economic interests.         Sincerely,


Tony Tweedale
224 E. Pine (2)
Missoula, MT 59802-4541
406-542-1709 tel. [& Fax--must call me 1st)]
ttweed@wildrockies.org

Causality is a concept not subject to empirical demonstration.
        -David Hume (1711-'76)
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