Chapter 18. Sarbanes-Oxley for Science A Dozen Ways to Improve Our Regulatory System

In the last chapter of the book, the author seems looking for the solution for his doubts in the public health issues he raised in the prior chapters. For the regulatory system in the United States, “the anarchic and overlapping division of responsibilities between the agencies” is considered the source of the chaos. He make the analogy between the 90’s Arthur Andersen scandal and the current science world; promote that there should be a Sarbanes-Oxley for Science to reform the federal legislation system in public health issues. To strength his opinion, he provides twelve recommendations. I would like to review all of his recommendations and raise some questions to these recommendations as following:

1. “Require Full Disclosure of Any and All Sponsor Involvement in Scientific Studies”
Considering the tendency of science link to the commerce, the author realize the situation that corporations block the publication of research and sponsors control the results of studies should be regulated. This recommendation has the similar purpose of Sarbanes-Oxley that provides a more transparent science world and independent research to increase the reliability of science research and publication.

Question:
a. As the author’s consideration, corporate money and grant are great parts of most scientific research funding, although some published journals have already promoted the ideas, if all the sponsors evacuate due to no interest and benefit from those research, is it a way to restrict the development of our science?

2. “Manufacturers Must Test Chemicals before Exposing Workers and the Public”
As the cases of environmental hazard reported before, most of them are found from the mode of “body in the morgue” method. However, the high risk expose environment is not that difficult to found. To improve the work-place environment, it might increase the cost of manufacturers, that might be the reasons most industries and manufacturers would rather they don’t know. The author consider EPA should have the right to require manufacturers conduct basic toxicity testing before the environment expose to workers and public.

Question:
a. As the description of the book, after the disclosure of high risk or toxic effect to workers and public, the manufacturers tend to solve problems by complain, ask for support from senators, and etc., when everything does not work, manufacturers still need to change after all. The money they spend on the others support which will not improve the actual situation will be great, why they do not consider maintain the environmental health at the first beginning?

3. “Manufacturers Must Disclose What They Know about the Toxicity of Their Products”
Even TSCA legislation has the requirement that all companies need to inform the EPA every adverse effect they found in the chemical exposure, the executive which conducted by some agencies cannot run this rule strictly. The “confidential business information” (CBI) becomes an umbrella for hiding adverse research result. The author suggests enabling legislation to regulate the report policies.

Question:
a. As the doubt to Sarbanes-Oxley Act, limiting the accounting and business confidential make the trade market more transparent, however, the complain about the Act restrict competition among companies never stop. How can we get the balance to maintain the confidential and competition when we promote the new Act?

b. I think most of manufacturers will tend to pursue benefit without bring harm to public. In the standpoint of the manufacturers, if they have the adverse result in the new product which they invest a great fund, who can afford the risk of fail?

4. “Put an End to Rigged Data Reanalysis”
As this recommendation, the private data reanalysis which is conducted by stakeholders or corporation related to the hazards should stop. Since the variability of epidemiology data analysis, any slight change of the indicator or methodology will change the analysis result dramatically, it is important for some quality data reanalysis in science, however, if the reanalysis is conducted by benefit related corporation, it might cause the confusion for public agencies and legislator’s judge.

Question:
a. Every manufactures will try their best to protect their benefit, when they raise a doubt about the public research result, how can the public agencies comfort this complain and doubt if only restrict the private data reanalysis?

5. “Hold Real People Accountable”
Providing a similar standard as the Sarbanes-Oxley Act, the author consider require the full disclosure of all administration board members and defined their specific responsibility in science research and legislator process can put an end to the intent ignorance of adverse results of science.

6. “Require Equal Treatment for Public and Private Science”
The unequal treatment between public and private studies is considered as the source of rigged data reanalysis and paralyzing the legislation process. For the public research, the laws require the agencies to consider the responsibility of making any comment and questions. However, the private studies which can get more resources will receive less restriction. The author suggests this model should be opposite advocate.

Question:
a. The public research face to more restriction and less funding sources, as the example of Marie and Pierre Curie and Wilhelm Roentgen (who discovered the x-rays), I feel great respect to their selfless contribution to human-being. However if science is only maintained by moral and consciousness, how can it survival for a long run?

7. “Protect the Independence of Federal Scientists and the Science Advisory Committees”
The financial ties to the scientists influence their judgments to those cord decision related to the benefit of manufacturers. Interest conflict also decrease the motivation of those top scientists involved into the independence and public research. The author suggested the federal agencies should reform that scientists who have financial conflict can only contribute ideas to conflict issues but no right to vote for the decision.

Question:
a. As I heard from the other respond, scientists who work in universities will tend to have a lower salary compare to the ones work in corporation or companies, I think this unequal treatment will cause more and more excellent experts leave the pure academic research and get involve into the sponsors’ conducted research. What do you think the further impact of this situation?

8. “Increase Public Disclosure of Hazards”
Shaming is a great regulation, as the term given by Mary Graham from Harvard’s Kennedy School of Government. The less public disclosure of hazards, the less manufactures would have motivation to change. The author suggests increasing public disclosure of hazards will be benefit for our society to inspect some corporations’ behavior.

Question:
a. As we all known, media which is a business will surely receive a great sponsor from different corporations, what can be the motivation for those media to disclosure a hazard related to their sponsors?

9. “Require Corporations to Make a Plan and Stick to It”
The author suggests each business should public their own plan to all employees and community to accept the inspection from public. It can decrease the diversity standard in timely agencies and the companies. At the same time, it can decrease the inspection process and make it more effective.

Question:
a. Who should be responsible to make this plan? If the employees and public haven’t realized a new hazards, how can we ensure the plan will work based on the benefit of workers and community?

10. “ALARA (As Low as Reasonably Achievable)”
Since the diversity of risk exposure level in different chemical material, so many chemical material do not have a standard for safe exposure level, the author suggests we should promote the “ALARA” which has already provide to radiation experts in all the other substances.

Question:
a. I think the vaguer of the standard, the more difficult for the public health agencies to provide inspection in our world. “ALARA” have a great purpose when it is founded, however, how can we provide it to all the other substances and maintain a well control of low risk exposure in work-place?

11. “Integrate the Control of Environmental and Workplace Toxic Exposures”
Although there are several different public health agencies tend to facilitate the inspection process and environmental health control, lack of consistent philosophy and repeat procedures will decrease the efficacy of the executive system. “Take Down the Stovepipes” might be a fast way to improve this situation.

Question:
a. I haven’t fully understand the administration and executive system in the United States, I think to decide which agency should be survival after the author’s proposal might be the next issue here. I wondering if there is somewhat centralization administration providing to this arrangement, was it more helpful for the system reform?

12. “Make the States Public Health Protection ‘Laboratories’”