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Remarks by Dr. Joshua Lederberg The Rockfeller University at the 1988 AINC Annual Meeting,

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Privileged to be invited to address you, here in Washington, at a major

12/7/88

 

turning point in the nation’s history. And a relief to be away from the
Gorbylock on traffic in NYC.

Over the weekend, I had started to put my thoughts together;before I had
spent a lot of time on my word processor, I recalled that I had received a
copy of Ed Behrens’ AIHC Transition Report to the American Agenda.
Luckily, I was able to find that paper in the mail pile, and I was pleased to
find an almost perfect congruence with what my own draft ideas. And this
is good for you: I can make my remarks fairly brief and to the point.
Having been working for some time on The Carnegie Commission on
Science & Technology and Government I had already been going over many

of the same issues.

What we have to say is not all that controversial: it is consistent with Pres.-
Elect Bush’s speech of October 25 to the Ohio broadcasters. Our task is
not to persuade but to remind Mr. Bush of the priority he voiced for

strong, credible, broadly based S&T advice in his new administration.

This may be redundant, but I will summarize the the main

recommendations of the Transition Report:

1. That the scientific basis for regulation be of peer-review quality.

2. That each of the agencies retain or engage external advisers, so as to call

on the broadest and best available talent.
3. A doctrine to separate technical judgments of risk assessment from the

political ones of risk management.

4. A mechanism for interagency coordination.

5. A strong S&T adviser to the President to oversee the implementation of

the above; to include a life scientist at a high level in the OSTP.

I imagine this audience would give only the most enthusiastic support to
these modest proposals. Some may criticize them for not going far enough
to relieve the industry of some of its most vexing harassments. In the back
of our minds for many of us may be the feeling that the last prescription,
the appointment of a well-qualified assistant to the president for S & T is
the key to all the others. Many professional groups have urged the same;
and I would add my own vote to the petition. We share the hope that it
will happen, and have good effect. But I will turn now to some of the
difficulties that the Science Adviser may face, and what else may be needed
to bring this country to a better balance as we face very difficult cost-risk-
benefit analyses. The first categorical is the understanding that we have no
choice about risk-cost-benefit tradeoffs. They happen as a consequence of
our choices, whether they arise out of conscious decision, revelation or any
other process. The only question is whether we seek to optimize any of our

values, or prefer to leave them to chance or whimsy.

We should begin with some elementary economic theory. Free enterprise --
# many advantages # inspiring innovation and investment in R & # even

more costly D. Unfortunately, this profit oriented system, the hidden hand
that turns the aggregate of private greed into the public benefit, also propels
safety validation into an adversarial mode. The party who is motivated to
undertake safety research is the one who will profit from the
commercialization of the product. Without that incentive, there is no
advocate for it. So we have two problems: There may be some orphans, ---
when there is insufficient self-interest owing to limited markets or profit
opportunities, say for a commodity, or perhaps owing to expiration of
patent monopolies. In other cases, the cat’s watching the pigeons! that is
excessive self-interest may cloud the professional ascertainment of the
relevant scientific data. The public’s confidence that industry has an
unremitting concern for the public’s welfare is hardly enhanced by the news
headlines on leveraged buyouts and hostile raids; and I have real anxiety
that top management’s preoccupation with defenses and poison pills may
leave real gaps in the unremitting oversight over middle management’s "can
do" spirit that is needed to forfend unprecedented environmental disasters,
when a misstep as simple as leaving salt out of a recipe can generate a

national tragedy over which everyone grieves for a long time.

No one today can possibly argue for abjuring all safety regulation; and as
onerous as this may sometimes appear, it may yet help to forfend still more
grievous torts actions. Unfortunately compliance with regulation is of
limited defense -- very bad public policy, in my own view. We tend to
ignore the orphans, though there would be a good argument to couple the

extremities of regulatory demands with the expected numbers of people at

risk.

Economic theory would say that we have efficient use of resources when the
overall health benefit of the regulatory process, through the aversion of
disease, exceeds its costs, both direct, and through the discouragement of
innovation. In practise, the market is unlikely to be so finely tuned, and the
resources available to, and the expectations of, special interests are more
likely to dominate. Those special interests include not only industrial
proprietors, but also those who make their livelihood as self-appointed
representatives of the public interest, even such bystanders as the press and
the machinery of politics. Even the research establishment can be accused
of a special stake in its appeal to "objective research"; but that will not
deter me from the claim that this is also very much in the public interest.
The net result is the kind of political embroil we have seen repeatedly,
which has resulted in the challenge to, and often overthrow of an almostly
randomly selected set of targets, which bear no relationship to any rational

assessment of their risks and benefits.

The science adviser then faces several daunting tasks. First, of course, is
the mobilization and coordination of scientific skills and policies across
government agencies. He must do this in the face of personnel and
compensation policies that have made government ever less attractive to
people of high technical skills, and we want precisely those who are NOT
motivated by any form of Potomac Fever as alternative reward. Why
should our best and brightest work for government, especially in the crucial
middle ranges; and if they do, why should they take any bureaucratic risks
of any kind? Do we have the science base to give robust answers to most of
the risk-assessment challenges facing us today? Industry today is, I believe,
spending much more in assessments for Super-Fund and waste site cleanup

than in toxicological research; and only a tiny portion of that trickles down
to the universities and to CIIT where the most fundamental work is done.
Scarcer still are the settings where one can see practised and learn the arts
of compiling diverse toxicological data and crafting a comprehensive risk
assessment from them. # Obstacles of extrapolation, need for comparative
toxicology ... Still a part of assessment are the economic costs and benefits
.. We can see how vanishingly rare are the settings for comprehensive

analysis. Where will people be trained for careers in government?

Then, the above accomplished, the Adviser must somehow give direction to
the risk-management side of government responsbility. Will agency
directors welcome having their judgment of the politically feasible
encumbered by the pronouncements of the risk-assessors? Where will the
votes come from to sustain rulings that seem to be on behalf of wealthy
corporations? The root problem is in public understanding. We have to be
appalled at the failure of scientific education at the most rudimentary level
among our people. Not just there! (C.P. Snow talked about this in the 2
cultures). How many legislators, or CEO’s for that matter, could tell you
about Avogadro’s number? Yet they must judge whether Delaney is
scientifically sustainable! The adviser must reach very far to the very roots
of our culture: probably the most important single repair needed in literacy
is a fair understanding of risk and quantitative probability theory. How
many will answer correctly: having tossed a fair coin and gotten 10 heads,
what are the odds for the next toss? What do you think are the odds for a
run of 10 or more heads in 100 throws? What do you think the public
reaction is to a run of three birth defects in a 1000 births, when the average

occurrence is nearly 1%? You can be sure a chemical will be blamed.
We can of course look to the president himself for leadership in policies
about science and education, perhaps even directly for leadership in the
very substance of these issues -- as we expect of him in equally grave and
complex matters of economics, human welfare and national security. That
expectation is part of our zeal for a high place of a Science Adviser in the
White House: we would like to see scientific competence close to the center
of political power. We have to be careful about the converse, how hard it is
to insulate such power from politics; and there may be many matters best
down-scaled, in a sense to protect the president from having to spend his
own political capital on adjudications that can be dealt with at lower, more
technical and more autonomous levels of government, -- precisely to insulate
those decisions from the unremitting tug of war of political forces. For that
reason, the AIHC transition team report is wise to stress elements of
integrative process and coordination in the functioning of the presidency,

the virtues of our high leadership notwithstanding.

May I add that comparable arguments may also apply to corporate
governance; that the CEO (especially of a high-tech firm where he may not
himself be technically qualified) may have a comparable need for a Science
Adviser, reporting directly to him. Unlike most government agencies, the
line organization of the corporation is more likely to have continued,
operational scientific experience to keep it in close touch with contemporary
scientific developments. Many companies also properly offer critical
autonomy to their safety, quality-control, and environmental divisions. But
in the U.S., the technical ladder often does not reach the topmost layers of
management. At any event, many corporations should consider whether

they do not need a "PSAC" to reach more broadly into the scientific
community for detached critical advice, both to enhance innovation and to
be sure no stone is left unturned in risk assessment -- before this becomes a

matter of broader public vulnerability.

I have high hopes for significant improvement, but not for radical
amelioration until we have dealt with some of the more basic issues of
human competence: the education of more professionals with cross-specialty
skills, and a radical improvement in scientific education of our public. For
the latter we must begin with the early grades, and it may be a dozen years
at best before we can see much impact on the quality of our politics, and

from there on that of our regulatory system.