Acknowledgments This report was researched and written by Laura MacCleery, with research assistance from Paul About Public Citizen Public Citizen is a non-profit, 150,000-member organization based in Washington, D.C. that Public Citizen 1600 20th St. N.W. public March 2001. ©2001 Public Citizen. All rights reserved. Graham Is At The Center of An Anti-Regulation, Corporate-Funded Network Graham's Risk Tradeoffs Are Political Cover for An Anti-Regulation Agenda Graham's Methods are Deeply Flawed And Antithetical to Environmental and At OMB, Graham Would Imbalance the Regulatory Process Expanding the Role of Risk Analysis and Cost-Benefit Analysis Undermines A Comparison of Graham's Risk Tradeoffs and the Corporations Following the Money: Graham's Affiliations with Other Organizations PART TWO: CASE STUDIES: GRAHAM GOES TO BAT FOR INDUSTRY. Letter from Tom and Ray Magliozzi, Hosts of Car Talk from National Public Radio Case Study #3: Graham Opines on Passenger-Side Air Bags Misleading Risk Communication: The Difference Between Falling Flack Science: Manipulating the Media Pays Off No Comment I: Consumers Union Letter to EPA And USDA About HCRA PART FOUR: APPENDIX... Appendix A: In His Own Words Appendix B: Full List of HCRA Funding Sources Appendix C: Graham's Record on the EPA's Dioxin Science Advisory Board Appendix D: Risk Assessment and Risk Management Appendix E: The Misuse of Comparative Risk "Analysis" How a Social Science Becomes Swiss Cheese Endnotes 99 99 102 109 110 113 115 116 ww EXECUTIVE SUMMARY News reports published the week of March 5, 2001 indicate that John Graham, founding director of the Harvard Center for Risk Analysis (HCRA), was nominated by President Bush for a position as the new regulatory czar in the White House Office and Management and Budget (OMB) Most Americans have never heard of John Graham, but if the U.S. Senate approves, he will be in a position to wield enormous power, and to undercut public health, safety and environmental protections for years to come. Graham would head the Office of Information and Regulatory Affairs (OIRA), which vets any significant or controversial regulation before it can be implemented. Over the past decade, Graham has been a prominent figure in the fight to halt or delay the issuance of protective safeguards by federal regulatory agencies, working with and receiving funds for his activities from dozens of major corporations. At OMB, he would be able to impose his will on the agencies, perhaps even on behalf of his former industry supporters, by blocking the development of standards and eviscerating the government's regulatory framework. There are three major problems with Graham's potential rise to power within OMB. First, Graham is certain to favor the regulated industries that have handsomely supported his Center Graham has amply demonstrated his willingness to ignore, or gloss over, his own conflicts of interest This report shows that Graham's Center has accepted money from chemical companies, auto manufacturers, energy and oil interests, and other industries hostile to regulation. Yet, invoking the prestige of Harvard University, he has consistently testified before Congress and been widely quoted by the media as though he is a neutral academic "expert," with no disclosure of the sources of his Center's funding in the article or testimony.2 As discussed in Part One: Who Is John Graham?, Graham's research has been used to lend a "scientific" veneer to corporate efforts to roll back safety and environmental standards, and to push for a top-down reorganization of the government's basic regulatory scheme. Graham's Center is funded by more than 100 large corporations and trade associations, including such known environmental offenders as Dow, 3M, DuPont, Monsanto and Exxon, in addition to the Chlorine Chemistry Council, the American Automobile Manufacturers Association, the American Petroleum Institute, and the Chemical Manufacturers Association, now called the American Chemistry Council.' High-ranking corporate officers from Oxford Oil, the National Association of Manufacturers, Eastman Chemical, Tenneco Inc., CK Witco Corp., and Novartis Corp. sit on the Center's Executive Board. The HCRA Advisory Council includes executives from DuPont and the Grocery Manufacturers Association, and the chief attorney for environmental affairs at Exxon Chemical Americas. Second, Graham's methodology appears to be informed more by the wishes of his corporate backers than by anything recognizable as "science." Although he often calls himself a "scientist," Graham's field of risk analysis is a discipline within the field of public policy, and he does not in fact hold any degrees in the hard science disciplines that often form the basis for regulatory policy As this report demonstrates, Graham's research conclusions are frequently marred by his inflation of industry costs and underestimations of the public benefits of safeguards. The practice of cost-benefit analysts also omits or downplays ethical and moral factors such as justice, consent and equity, and inappropriately discounts the value of human life and the environment. |