in publicly and privately supported science, asserted Michaels. Full disclosure implies having this information available to the public and not just leaving the decision about managing conflicts of interest to the judgment of an agency or an editor. Disclosure needs to encompass the entire research enterprise and needs to be applied equally to the publishing of research and the regulatory setting.

THE CREDIBILITY OF SCIENCE

Protecting scientific integrity and credibility given human fallibility is an ongoing challenge. Ultimately, all scientific findings must be judged on their merits, whatever the source of funding, argued Myron Harrison of ExxonMobil Corporation. In an ideal world, the people who sit in judgment should not have conflicts and should have the best expertise to render a decision. However, they need to be guided by an established set of rigorous criteria that must be equally applicable to research from all sources.

It is a reality that the science used in public health is particularly unstable and uncertain, and therefore scientific disagreement and controversy should be expected. In the face of this uncertainty, other human factors, such as personal beliefs and values, often play a large role. Scientists are not usually trained in methods, such as argumentation, that try to establish particular and contingent “truths” in the realm of human affairs. Thus, there is often a misuse of empirical evidence to support decisions that are primarily value based, noted Harrison.

The challenge remains: How can an agency optimize the credibility of science used in rule making? Some characteristics of good research can strengthen its credibility:

  • Using good lab practices and good epidemiological practices, which include such tools as research protocols, auditable data management practices, and publication of all results.1

  • Protecting human subjects in all settings, including private institutions (oversight by institutional review boards also addresses the value and quality of research).

  • Applying rigorous peer review not only for the purposes of journals, but also separately in the rule-making process.

  • Disclosing all potential conflicts of interest.

  • Implementing strong management systems, including external reviews, to oversee the priorities and conduct of the research program.

1

There is a basic challenge to publishing all data, as studies reporting negative findings (lack of an effect) are more difficult to publish in peer-reviewed journals than those that show an effect.



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