August 15, 1995
EPA-SAB-EC-COM-95-004
Ms. Carol Browner
Administrator
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
RE: Commentary on SAB Completing Peer Reviews
Dear Ms. Browner:
The Science Advisory Board (SAB) is pleased to serve you as a peer reviewer of
technical Agency workproducts that are associated with some of the more contentious
issues facing EPA. Recent examples of such reviews include the risk assessments for
dioxin, environmental tobacco smoke, and electromagnetic fields. In addition, the SAB
applauds your articulation of a Peer Review Policy that was issued in June, 1994.
We are writing to clarify our understanding of the application of the Peer Review
Policy to reviews conducted by the SAB. Specifically, some people have read the Peer
Review Policy as indicating that, once the SAB has reviewed an Agency document, the
Board should not "take a second look" at the document following alterations made by
the Agency at the suggestion of the SAB.
We believe that such an interpretation is incorrect and that, in many instances,
the SAB's being able to assure you that the Agency position on an issue rests on
"sound science" demands that the Board have the opportunity to examine how its
advice was taken, interpreted, and used in the final document.
There are several reasons for our feeling so strongly about this point:
a) The SAB is simply completing its job by seeing whether its advice has
been appropriately understood. The Board acknowledges that perhaps
not all of its advice will be taken. However, in such cases, it expects that
the Agency will articulate the reason for not taking that advice.
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b) There is precedent for the re-review in that peer reviewers of journal
articles are sometimes-but not always-asked by editors to review the re-
drafted article to see if their original concerns have been addressed.
c) There is also ample precedent in the operation of the SAB over the past
1 5 years.
d) To proceed to a second, non-SAB panel for the subsequent review is to
invite, at best, an endless loop of new changes-generally of second order
importance-and, at worst, subjecting the document to double jeopardy,
often at the hands of reviewers who are less well-versed in the some
aspects of the subject than the first panel of experts.
e) Strict exclusion of the primary reviewers is to guarantee a loss of
historical perspective.
f) By going to a non-SAB panel, the Agency would be subject to a charge of
"shopping around" to find a panel of a particular bent.
As the record shows, more often than not, the SAB does not have the luxury of
taking a second look. In part, this situation is connected with limitations on resources
of our members and resources of the Agency to carry through reviews to that level of
precision. However, for those particularly contentious issues, a final verification by the
SAB is good for the Board, good for the Agency, good for the environment, and good
for the public whom we all serve.
I appreciate your attention to this matter and your response to the concerns we
have raised. We look forward to continuing the productive working relationship
between EPA and the SAB in the future.
Sincerely,
Dr. Genevieve Matanoski, Chair
Science Advisory Board
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