Belzer Regulatory Chkbk
NO MERRI
sab epa off bs
Belzer, Richard Independent consultant Since 2001, Dr. Richard Belzer has been an independent consultant in regulation,risk, economics and information quality. Previously he was a visiting professor of public policy at Washington University in St. Louis and staff economist in theOffice of Information and Regulatory Affairs in the Office of Management and Budget. He received his Ph.D. in public policy from Harvard University (1989), Master’s in Public Policy (MPP) from the John F. Kennedy School of Government (now Harvard Kennedy School) (1982), and MS and BS degrees in agricultural economics from the University of California at Davis (1979, 1980). Current original research areas include the analysis of variability in pulmonary function testing; the development of objective economic indicators to identify adverse human health effects; the improved use of human health risk assessments into benefit-cost analysis; the analysis of environmental justice ranking schemes; the analysis of patent law and examination practices; estimation of potential cost reductions state Medicaid programs from the substitution of electronic for tobacco cigarettes; and the economic value of subjective quality information in U.S. wine markets.
Recent consulting projects have included benefit-cost analyses of California’s proposed drinking water standards forhexavalent chromium and 1, 2, 3- trichloropropane; and the critique of predicted human health impacts and monetized risks attributable to air emissions from new facilities designed to achieve federal regulatory standards. Dr. Belzer is a regular contributor to scholarly professions through journal peer review and service to professional societies. He was elected Treasurer of theSociety for Risk Analysis (1998, 2000) and elected Secretary-Treasurer of the Society for Benefit-Cost Analysis (2008, 2010). He earned multiple awards for exemplary performance at OMB, given the SRA’s Distinguished Service Award (2003), and named a Fellow of the Cecil and Ida Green Center for the Study of Science and Society (1995). He has not received any grants from EPA, any other government agency, or any private entity. He has conducted independent research on behalf of clients or through self-funding. Some projects are jointly funded. His clients include: Council of Producers & Distributors of Biotechnology, R Street Institute, Exxon Mobil Biomedical Sciences, In
exxon knew
bs bio
Who Is Richard Burton Belzer?
I don't play a cynical detective on television.
I never met Elizabeth Taylor.
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Who Not to Pick for the EPA’s Science Advisory Board
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GENNA REED, LEAD SCIENCE AND POLICY ANALYST | SEPTEMBER 26, 2017, 3:27 PM EDT
In its effort to fill fifteen positions on the Science Advisory Board, the EPA has posted a listof 132 nominees to be a part of the esteemed EPA Science Advisory Board (SAB). The SAB is a group of over forty scientists, experts in a range of disciplines, who provide peer review and expert advice on EPA issue areas.
While many of the nominees are highly qualified and distinguished in their fields, there are a handful of individuals that are extremely concerning due to their direct financial conflicts, their lack of experience and/or their historical opposition to the work of the EPA in advancing its mission to protect public health and the environment.
The SAB was established by the Environmental Research, Development, and Demonstration Authorization Act of 1978 and operates as a federal advisory committee under the Federal Advisory Committee Act of 1972. Note that board members should be experts in their fields, with the training and experience to evaluate EPA-relevant scientific and technical matters. Source: U.S. GPO
Many of these concerning individuals were nominated by Heartland Institute—an organization that has actively worked to sow doubt about climate change science—and have the seal of approval by Trump EPA transition team member and Heartland staffer, Steve Milloy. When interviewed about some of the names on the nominee list, Milloy said that he is glad that EPA administrator Scott Pruitt is in office since he’ll be brave enough to reconstitute the SAB. A “thumbs up” from Milloy is an immediate red flag for me.
My colleague, Andrew Rosenberg, categorized questionable political appointees in three distinct buckets: the conflicted, the opposed, and the unqualified. The same can be said of nominees for the SAB. You don’t have to dig too deep to find individuals who may appear to be qualified on paper, but have a track record of undermining the work of the EPA and advancing policies that benefit special interests over the general public. Appointing these individuals to the SAB would be in direct opposition to the critical work of the SAB itself and to the EPA’s mission.
Take Dr. Michael Honeycutt, lead toxicologist at the Texas Commission on Environmental Quality, for example. Industry representatives, including at the American Chemistry Council, ExxonMobil, and the Texas Oil and Gas Association launched a campaign to get Honeycutt appointed to the CASAC in 2016, which fortunately was unsuccessful. Now Honeycutt’s name is on the list for the SAB.
He co-authored an article in 2015 that argued that available science did not support the EPA’s assertion that tighter ozone standards would provide significant public health benefits. In criticizing the scientific studies used by the EPA, Honeycutt has cherrypicked studies to exaggerate uncertainty on risks of ozone pollution, including making hay of the argument that ozone pollution isn’t a huge issue because “most people spend more than 90 percent of their time indoors,” which has been picked up and spouted off by climate deniers, like Michael Fumento.
Honeycutt has also served on the steering committee of the Alliance for Risk Assessment (ARA), along with President Trump’s nominee to head the Office of Chemical Safety and Pollution Prevention, Michael Dourson. The ARA was created by the TERA, an organization founded by Dourson that does research for industry and maintains a database of risk assessments.
According to its website, about a third of TERA’s funding comes from the private sector, including the American Chemistry Council and Coca-Cola. Rena Steinzor, professor at the University of Maryland School of Law has accused TERA of “whitewashing the work of industry.” The TCEQ has awarded TERA at least $700,000 in contracts between 2010 and 2014. As a steering committee member, Honeycutt oversaw ARA scientific reviews of TCEQ work. While Honeycutt claims that he recused himself from those projects, the quagmire of ties between TCEQ, ARA, and TERA are hard to dispute, especially when you consider that during those same years, the TCEQ loosened two-thirds of the already-weak protections for the 45 chemicals it chose to reassess between 2007 and 2014. In 2013, The TCEQ paid $1.6 million to another industry-friendly consulting firm, Gradient, to review EPA’s science on ozone.
Honeycutt has spent his career at TCEQ politicizing the EPA and actively working to obstruct science used to inform important standards at the agency, so it seems out of character for him to want so badly to be a member of an EPA science advisory committee. Unless, of course, he is interested in the platform or the ability to provide formal advice to his personal friend, Michael Dourson.
What does Honeycutt have in common with fellow nominee, Dr. John Graham? Under Graham’s leadership in January 2006, The White House Office of Management and Budget (OMB) released a proposedRisk Assessment Bulletin which would have covered any scientific or technical document assessing human health or environmental risks.
OMB asked the National Academy of Sciences’ National Research Council (NRC) to conduct an independent review of the document. Its study gave the OMB a failing grade, calling the guidance a “fundamentally flawed” document which, if implemented, would have a high potential for negative impacts on the practice of risk assessment in the federal government. Among the reasons for their conclusions was that the bulletin oversimplified the degree of uncertainty that agencies must factor into all of their evaluations of risk. This idea for standardized risk assessment is of interest to regulatory reform advocates like Graham and has made its way into the dangerous Regulatory Accountability Act in Congress and into the new toxic substances rules under the Frank Lautenberg Chemical Safety for the 21st Century Act that Graham’s protégé and former ACC staffer, Nancy Beck, is now crafting from her position as Deputy Assistant Administrator of the EPA.
Before his stint at OMB, Graham led the Harvard Center for Risk Analysis, which notably skewed risk analyses in favor of industry: costs saved by not regulating versus lives saved regulating. In one case, Graham’s OMB rejected a National Highway Transportation Safety Administration rule that would reduce the toll of vehicle rollovers by requiring that automakers install tire pressure warning systems. Graham made this decision despite the direct conflict of interest as his Harvard think tank was funded by General Motors Corp., Ford Motor Co., Volvo Car Corp. and the Alliance of Automobile Manufacturers.
Another individual that the SAB should steer clear of is Dr. Richard Belzer,an agricultural economist and, like Graham, is a cost-benefit-analysis enthusiast who worked for the OMB’s Office of Information and Regulatory Affairs (OIRA) from 1988 to 1998. In 2000, Belzer criticized SAB’s role in peer reviewing the EPA’s evaluation of costs and benefits of the Clean Air Act. Belzer and his co-author called SAB’s reviews “ineffective” because, in their opinion, they couldn’t force the agency to change the direction of policy.
Belzer appears to misunderstand the purpose of the SAB which is to simply advise the agency on its science. The EPA has the discretion to heed that advice and apply it to policies. SAB members are not decision-makers, they are esteemed scientists whose expertise is best suited to evaluate scientific considerations, not political ones. In 2010, Belzer participated in a panel on “The EPA’s Ambitious Regulatory Agenda” sponsored by the American Enterprise Institute, the description of which includes the erroneous statement: “all major EPA decisions are contentious.” According to his bio, his clients include ExxonMobil and American Chemistry Council. And speaking of American Chemistry Council…
Kimberly White, senior director of chemical products and technology at the ACC is among those nominated to serve on the SAB. She has been summoned by House Science Committee Majority Staff, Lamar Smith, to testify at the hearing called “Making EPA Great Again” earlier this year where she spoke about the need to improve the SAB’s transparency and peer review methods and accused the EPA of being too involved in the SAB’s peer review process: “conversations that are happening in that peer review get stymied by [the] EPA’s input during the peer-review process so it’s not as independent as it should be.”
She also agreed when one member of congress suggested that the SAB was not truly balanced and that there should be a devil’s advocate on the committee. Perhaps Dr. White wants to fill that very role. The problem with that, however, is that the American Chemistry Council and her previous employer, the American Petroleum Institute, are organizations that actively work to spread disinformation about a range of scientific topics to thwart the EPA’s work to keep us safe. Dr. White has criticized an EPA assessment on formaldehyde, for example, because it wasn’t inclusive enough of science. Formaldehyde is a known carcinogen and thanks in large part to ACC, the EPA’s emissions standard for wood products set to be enforced in December has been delayed at least four months.
Who Pruitt appoints for the fifteen open positions will be a test to see whether he is going to continue seeking exclusive counsel from polluters. There are a handful of qualified scientists who have only served one term that can be easily reappointed for a second, which is common practice for the board. For the sake of continuity, it would behoove Pruitt to keep those experts on. For the other positions, it would be in the agency’s best interest for Pruitt to choose a balanced roster of new members from the dozens of well-qualified scientists on the list, rather than stack the committee with folks who have spent their careers working to undermine the mission of the EPA and weaken policies that are supposed to keep us safe.
All members of the public can submit comments encouraging the EPA to appoint independent and qualified scientists as advisors. You have until Thursday, September 28th at 11:59pm to email your comment to Thomas Carpenter, the Designated Federal Officer of the SAB, at carpenter.thomas@epa.gov.
Posted in: Science and Democracy Tags: American Chemistry Council, American Petroleum Institute, EPA Science Advisory Board, Heartland Institute, OIRA, Regulatory Reform, Science Advisory Committees
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The Fix Is In: EPA Packs Science Advisory Boards with Industry ...
https://www.environmentalintegrity.org/news/epa-packs-sab-with-industry/
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Nov 3, 2017 - Both the SAB and the CASAC were created by Congress in the 1970s to provide ... John D. Graham also has a dangerous ideological agenda.
Who Not to Pick for the EPA's Science Advisory Board - Union of ...
https://blog.ucsusa.org/.../who-not-to-pick-for-the-epas-science-advisory-b...
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Sep 26, 2017 - The SAB is a group of over forty scientists, experts in a range of ... does Honeycutt have in common with fellow nominee, Dr. John Graham?
In unprecedented move, EPA to block scientists who get agency ...
https://www.washingtonpost.com/.../in-unprecedented-shift-epa-to-prohibit-s...
Oct 30, 2017 - John D. Graham, who now serves as dean of Indiana University's ... would allow for a dialogue on how best the SAB can work to ensure the ...
EPA's new science advisers add more industry experts, conservatives ...
https://www.washingtonpost.com/.../pruitts-new-science-advisers-add-more-i...
Nov 4, 2017 - The 44-member SAB has two representatives from environmental groups: the ... John D. Graham, who worked to raise the bar for new federal ...
[PDF]
June 28, 2018 EPA-SAB-18-003 The Honorable E. Scott Pruitt ...
https://yosemite.epa.gov/sab/sabproduct.../EPA-SAB-18-003+Unsigned.pdf
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Jun 28, 2018 - Subject: Science Advisory Board (SAB) Consideration of EPA .... Dr. John D. Graham, Dean, School of Public and Environmental Affairs, ...
Trump-Pruitt EPA Vets Industry Anti-Scientists for SAB | NRDC
https://www.nrdc.org/.../trump-pruitt-epa-vets-industry-anti-scientists-sab
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Sep 28, 2017 - John Graham - Founding director of the Harvard Center for Risk Analysis which was partially supported by tobacco, chemical, pharma and ...
From 1988-1998, I was a staff economist at the Office of Information and Regulatory Affairs, the small unit within the U.S. Office of Management and Budget that reviews draft regulations before they are published for public comment or promulgated as rules. He was responsible for reviewing (and improving the quality of) regulatory analyses prepared by the Environmental Protection Agency, the Food and Drug Administration, and various components of the Departments of Agriculture, Commerce, Energy, and the Interior.
From 1998-2001, I was visiting professor of public policy at Washington University in St. Louis and director of the regulatory studies program at the University's Weidenbaum Center.
I earned my master's in agricultural economics from the University of California (Davis) in 1980, my master's in public policy from the Harvard Kennedy School in 1982, and my doctorate in public policy from Harvard University in 1989.
For most publications, presentations, and testimony that do not precede the Internet era, click on the Library tab on the upper right. For a curriculum vitae, click on the Contact tab.
Service to the Profession
- Elected Treasurer, Society for Risk Analysis (1998, 2000)
- Elected Secretary/Treasurer, Society for Benefit Cost Analysis (2008, 2010, 2012)
- Elected Treasurer, Society for Benefit Cost Analysis (2014)
Awards
- Special Award for Performance, Office of Management and Budget (1990)
- Division Award, Office of Management and Budget (1991, 1992, 1993)
- Senior Fellow, Cecil and Ida Green Center for the Study of Science and Society, University of Texas-Dallas (1995)
- Outstanding Service Award, Society for Risk Analysis (2003)
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PERC and cancer
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The Report on Carcinogens: What Went Wrong and What Can Be Done to Fix It
Regulatory Checkbook President Richard B. Belzer recently published a monograph analyzing the National Toxicology Program's biennial Report on Carcinogens. The monograph shows why the RoC, as it is called, has failed to live up to its congressionally intended purpose. Reforms are proposed that, if enacted, would restore science to its intended role. Without such reforms, the RoC will continue to misinform public and private decision-making. |
bs
Since 2001, Regulatory Checkbook has performed scholarly research on information quality; regulatory science, economics, and procedure; and paperwork reduction. Each of our separate programs is highlighted by a tab on the left.
The federal Information Quality Act directed the US Office of Management and Budget (OMB) to issue government-wide regulations or guidelines "for ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical information) disseminated by Federal agencies." The law requires OMB to direct agencies to establish administrative systems whereby affected persons (essentially anyone) may seek and obtain the correction of error. The OMB Guidelines were finalized in Febrary 2002. By October 1, 2002, each federal agency was required to issue its own agency-specific guidelines modeled on (and consistent with) the OMB Guidelines.
Regulatory Checkbook maintains a database consisting of every publicly-available error correction request submitted to each federal agency. As of September 30, 2010:
- 215 error correction requests were submitted.
- Agencies had responded to 193 of them after an average delay of 138 days.
- 61 agency responses were appealed.
- Agencies had responded to 46 appeals.
REGULATORY OVERSIGHT
Regulatory Checkbook's initial foray into regulatory oversight was the design and implementation of a scheme for grading regulatory impact analyses prepared by federal agencies. This scheme established what at the time was considered a generous standard for satisfactory performance. For example, to earn a grade of F, an agency regulatory impact analysis had to include an error so great that an agency head reasonably in tune with Congressional instructions, as contained in the statute delegating legislative authority to the agency, plausibly would have made a different decision. It was discovered that errors of this magnitude were endemic, thus destroying the grading scheme's ability to distinguish between high- and low-quality work.
Our sister nonprofit organization, Neutral Source, was established in 2006 to provide a venue for more informal communications on these issues. Both Regulatory Checkbook and Neutral Source do not engage in advocacy on substantive regulatory matters.
http://www.regulatorycheckbook.org/publications.html
- Belzer RB. 2012: "The Report on Carcinogens: What Went Wrong and What Can Be Done to Fix It," CEI Issue Analysis, 2012:1, Competitive Enterprise Institute.
- Belzer RB. 2009. “Principles for an Effective Regulatory Impact Analysis Challenge Function,” PRI Horizons 10:3, 31-39.*
- Belzer RB, Bus JS, Cavalieri EL, Lewis SC, North DW, Pleus RC. 2008. “The Naphthalene State of the Science Symposium: Objectives, Organization Structure, and Charge,” Regulatory Toxicology & Pharmacology 51:2(1), 1-5.*
- Belzer RB, ed. 2008. “Supplement: The Naphthalene State of the Science Symposium,” Regulatory Toxicology and Pharmacology, 52:2(1), 1-50.*
- Belzer RB, Bruce GB, Peterson MK, Pleus RC. 2004. “Using Comparative Exposure Analyses to Validate Low-Dose Human Health Risk Assessment: The Case of Perchlorate.” In Linkov I, Ramadan AB, eds. Comparative Risk Assessment and Environmental Decision Making, Kluwer, 57-74.*
- Cavalieri EL., Berndt WO, Pleus RC, Belzer RB, Mattie DR. 2005."Report of the Planning Committee for the Perchlorate State of the Science Symposium," Report for the Department of Defense, Office of the Secretary.
- Belzer RB, 2002.“Exposure Assessment at a Crossroads: The Risk of Success.” Journal of Exposure Analysis and Environmental Epidemiology 12, 96–103.*
- Belzer RB, deFur P, Clarke D. 2001. “Selecting, Implementing, and Tracking Ecological Risk Management Decisions: Necessary Elements of an Effective Decisionmaking Framework,” Chapter 5 in Risk Management: Ecological Risk-Based Decision-Making, Stahl RG, et al., eds. Pensacola, Fla: Society of Environmental Toxicology and Chemistry, 57-74.*
- Belzer RB, 2001. “Using Economic Principles for Ecological Risk Management,” Chapter 6 in Risk Management: Ecological Risk-Based Decision-Making, Stahl RG et al., eds. Pensacola, Fl.: Society of Environmental Toxicology and Chemistry, (75-90).*
- Belzer RB. 2001. “Getting Beyond ‘Grin and Bear It’ in the Practice of Risk Management,” Reliability Engineering and System Safety, 72:2, 137-148.*
8/15 ggl
Regulatory cancer risk assessment based on a quick estimate of a ...
www.ncbi.nlm.nih.gov/.../10049793
National Center for Biotechnology Information
by DW Gaylor - 1998 - Cited by 27 - Related articles
Regul Toxicol Pharmacol. 1998 Dec;28(3):222-5. Regulatory cancer risk assessment based on a quick estimate of a benchmark dose derived from the maximum ...
Missing: checkbook belzer perc
Regulators of genetic risk of breast cancer identified by integrative ...
www.ncbi.nlm.nih.gov/.../26618344
National Center for Biotechnology Information
by MA Castro - 2016 - Cited by 3 - Related articles
Nov 30, 2015 - Regulators of genetic risk of breast cancer identified by integrative network ... We created a breast cancer gene regulatory network comprising ...
Missing: checkbook belzer perc
Tetrachloroethylene (Perchloroethylene) | Technology Transfer ...
https://www3.epa.gov/.../tet-ethy.html
United States Environmental Protection Agency
Feb 23, 2016 - Tetrachloroethylene (Perchloroethylene) ... It is not an estimator of risk but rather a reference point to gauge the potential for effects. ... Cancer Risk: ... OSHA numbers are regulatory, whereas NIOSH, ACGIH, and AIHA ...
Missing: checkbook belzer
[PDF]Reviving Regulatory Reform - The Center for Regulatory Effectiveness
thecre.com/pdf/20050328_4446.pdf
by M Lewis Jr - 2005 - Related articles
Mar 28, 2005 - and risk-assessment as touchstones of regulatory decision-making, they also ......Belzer also notes that, “huge areas of formal regulation are missing” from ..... pesticides even though the cancer risks were negligible or based solely on animal ...... Dr. Richard Belzer, President,Regulatory Checkbook.
[PDF]2012 ANNUAL MEETING - The Society for Risk Analysis
www.sra.org/sites/default/.../2012_SRA_AM_abstracts.pdf
Society for Risk Analysis
P.72 Non-cancer Risk Assessment of 1, 3-Butadiene: Draft Acute and Chronic Reference Exposure Levels for ...... T3-C.6 Belzer, RB; Regulatory Checkbook;.
[PDF]Final Program - The Society for Risk Analysis (SRA)
sra.org/sites/default/files/pdf/Final_Binder_1.pdf
Society for Risk Analysis
Belzer RB. Regulatory Checkbook. 10:30 AM-Noon. Commonwealth B ..... Assessment of female lung cancer risk ..... approach for estimating cancer risks ...... Estimates of low-dose carcinogenic potencies for perc made by U.S. EPA, the.
[PDF]Informing Regulatory Decisions - The White House
https://www.whitehouse.gov/sites/default/.../2003_cost-ben_final_rpt.pdf
White House
Sep 25, 2002 - Agencies such as EPA often define acceptable lifetime cancer risk as a range from one in ..... The analysis compared regulating perc exposure at three different levels of decision ...... Richard B. Belzer,. Regulatory Checkbook.