May 9, 2001
The Honorable Members
Senate Governmental Affairs Committee
United States Senate
340 Dirksen Senate Office Building
Washington, DC 20510Dear Senators,
We write as scholars of law, medicine, economics, business, public health, political science, psychology, ethics and the environmental sciences to oppose the nomination of John Graham to direct the Office of Information and Regulatory Affairs (OIRA) at the Office of Management and Budget. We hope that the Governmental Affairs Committee will conclude that Professor Graham is the wrong person to supervise the nation’s system of regulatory safeguards.
Professor Graham’s controversial risk management methodology discounts the real risks of well-documented pollutants such as dioxin and benzene, and makes use of extreme and highly-disputed economic assumptions. Professor Graham has shown his willingness to over-ride health, safety, environmental, civil rights, and other social goals in applying crude cost-benefit tools far past the point at which they can be justified by existing scientific and economic data.
In his statements to the media and Congress, he has undermined regulatory efforts by understating many of the potential benefits of health, safety and environmental regulation and overstating their costs. Moreover, Professor Graham has publicly rendered many opinions on complex and imperfectly understood scientific phenomena, such as the etiology of cancer and other diseases, despite his lack of a degree in the hard sciences.
Graham’s work has, overall, demonstrated a remarkable congruency with the interests of regulated industries. In contrast, the position at OIRA requires a much more even-handed approach. Reviewing officials should respect the democratic process by which Congress assigns legislative mandates to the agencies, consider the investment of the public and stakeholders in the regulatory process and its results, and defer to the expert technical and scientific judgments of federal agencies.
We also have serious concerns about Professor Graham’s disregard for widely-accepted fundraising and research norms within academia. He has solicited and accepted unrestricted funds from corporations with a direct financial interest in particular regulatory issues addressed by his work, without acknowledging the role of his corporate benefactors. Unlike many research scientists, he has often operated without the guidance of restricted-funding contracts designed to minimize conflicts of interest and to protect credibility and public trust.
Graham’s record shows that he is unlikely to serve as an honest broker as OIRA director. Because we view his candidacy as an invitation for undue industry influence in the regulatory process and as a vehicle for application of a highly controversial methodology, we urge you to oppose John Graham’s nomination to Administrator of the Office of Information and Regulatory Affairs.
Sincerely,
Frank
Ackerman, Ph.D. Barbara A. Babcock Dr. John H. Baldwin Candice Bauer Lisa A. Bero, Ph.D. Amanda Behrens Patricia Blanchette John Bonine David C. Christiani, M.D. Richard Clapp Michael H. Davis Martin Donohoe, M.D., F.A.C.P. David Driesen Paul Farmer, M.D., Ph.D. Thomas G. Field, Jr. James K. Galbraith John Gartner, Ph.D. Eileen Gauna Linda Ginzel Robert Glicksman Leonard Greenhalgh, Ph.D. Matthew R. Glucksberg Sam Glucksberg Claude Guillemard |
Michael R. Harbut, M.D.,
M.P.H., F.C.C.P. Michael P. Healy Philip Johnson-Laird Boaz Keysar Professor R. A. Kinchla Howard A. Latin Thomas McGarity Don Milton, M.D., Dr.P.H. Paul Mushak, Ph.D. Herbert L. Needleman, M.D. Jerome A. Paulson, M.D. David N. Pellow, Ph.D. Zygmunt J.B. Plater, S.J.D. Adrienne Randolph, M.D., M.Sc. Lynne M. Reder John Rosen, M.D. Kristin Shrader-Frechette Steven Sloman Mark Squillace Rena Steinzor Sandra R. Waxman
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