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De Omnibus Dubitandum - Lux Veritas

Showing posts with label IQA. Show all posts
Showing posts with label IQA. Show all posts

Wednesday, April 5, 2023

Restoring trust in government by using the IQA

America deserves quality information that is accurate, objective, unbiased and reproducible

William L. Kovacs

The Federal government has left citizens living in information confusion, misinformation and conspiracy theories. Information clutter helps explain why only two in ten Americans trust Washington to do the right thing. But distinguishing between good and bad quality information should never be difficult when the information comes from our government.

There is a U.S. law that mandates that government-disseminated information be accurate and useful and have integrity. The federal government just refuses to abide by the Information Quality Act (IQA), section 515 of the Treasury and General Government Appropriations Act for FY 2001.

The Information Quality Act is designed to foster trust.

The IQA requires that the Office of Management of Budget (“OMB”) ensure and maximize “… the quality, objectivity, utility and integrity of information (including statistical information) disseminated by federal agencies.”

In 2002, OMB issued detailed guidelines defining the IQA terms. Information disseminated by the government was to be accurate (precise, complete and unbiased); useful to intended users; and possessing integrity (protected from manipulation). OMB also set forth a correction process for citizens, including experts, to challenge data inaccuracies.

For influential scientific information, there must be a "high degree of transparency about data and methods to facilitate the reproducibility of such information by qualified third parties." IQA procedures were designed to build trust in government information by following a modified scientific method of testing and reproducibility of data.

Information was defined as “any communication or representation of knowledge such as facts or data, in any medium or form.” Dissemination of information to the public includes agency distribution of information to the public.

While opinions are not covered by the IQA, when it is presenting an opinion instead of information, the agency must clearly identify it as an opinion.

Had IQA guidelines been followed during Covid, for example, the federal government would have provided the public with more useful information.

By not following IQA guidelines during Covid briefings, misinformation and opinion were often presented as fact, without any supporting documentation or without the statement being noted as opinion. 

As a result, citizens were forced to live in lockdowns, masks were mandated, schools were closed, causing massive learning losses, and natural immunity was deemed a conspiracy theory. Government agencies issued mandates, but provided little supporting information and never presented what levels of uncertainty were involved.

The Biden administration waffled between Presidential statements that it was seeking evidence-based information on Covid’s origins – and the unequivocal statements of leading scientist Dr. Anthony Fauci, who pronounced that it came from an animal.  After several years of delay, the FBI and Energy Department finally informed the public that “the Covid pandemic most likely arose from a [Wuhan] laboratory leak,” not from animals.

This served yet again to highlight the difficulty of believing the federal government.

Federal public guidance consisted of Dr. Fauci communicating inconsistent health-related information. First he told the public, “There’s no reason to be walking around with a mask.” A few weeks later, he supported universal masking. Subsequently, he endorsed double masking.

Then, as independent scientists offered contrary views, Fauci and his boss, Francis Collins, formulated a press strategy to discredit the credibility of their leading critics, by labeling them conspiracy theorists.

Federal misinformation fostered a state of fear. Eventually, state Attorneys General brought a lawsuit over the legality of Fauci's mask mandates. In depositions, Fauci could not identify any study he relied upon to support his conflicting policy pronouncements. And when asked direct questions about his knowledge of the virus’s origins or tests supporting his conclusions, he said he “could not remember.”

Such misinformation harmed public health. Not surprisingly, a recent Lancet study found that public trust in government is vital to effectively implementing public health measures.

Since its enactment, the federal government refused to implement the IQA.

From the moment OMB issued the IQA guidelines, federal agencies fought to undermine its implementation. Agencies viewed OMB’s guidelines as discretionary. The Department of Justice supported the agencies in court filings.

The public filed lawsuits against agencies to implement the guidelines and correct inaccurate information. These efforts failed. The courts avoided interpreting the substance of the statute, holding that private parties lacked standing to enforce IQA requirements. The federal courts gave agencies complete discretion on the type of information disseminated to the public.

With strong resistance from the federal government, the IQA drifted into obscurity. It is amazing that on something as vital as public health issues, courts failed or refused to recognize that citizens can be directly injured by public health misinformation.

Imagine if federal agencies followed IQA.

If the IQA had been implemented during Covid, federal agencies would have been limited to disseminating only reliable, consistent, reproducible information – or disclose that the agencies did not have supporting data. Under the IQA, “Mr. Science,” Dr. Fauci, would have been required to inform the public that his daily statements were mere opinions. The public would have known the truth, which would have allowed people to seek guidance from knowledgeable health professionals.

Government health misinformation is propaganda. Fortunately, it can be immediately remedied.

Government information permeates all of our society, from healthcare to climate change, nutrition and labor statistics. Good quality information is essential for protecting government agencies themselves, as well as families, businesses, schools, hospitals and society as a whole.  

When government presents misinformation or mere personal opinion as the truth, it harms the citizens it has sworn to protect. When agencies present computer models as evidence (or proof) that we face imminent manmade climate disasters, they likewise harm our economy and lives, unless the models’ results are confirmed by real-world observations, measurements or data.

Fortunately, the government misinformation can be immediately remedied. President Biden could today order OMB to implement the statute by reinstating and enforcing the original IQA Guidelines.

Moreover, Congress could codify the 2002 guidelines and clarify that citizens suffer injury when government misinformation harms their ability to protect their health, livelihoods and welfare.

William L. Kovacs is author of Reform the Kakistocracy, winner of the 2021 Independent Press Award for Political/Social Change. He served as senior vice president for environment, technology and regulatory affairs at the U.S. Chamber of Commerce.

Tuesday, April 4, 2023

Deep State Corruption, Death and the Information Quality Act

By Rich Kozlovich 

As a former owner of a pest control company, for 30 years I was involved in my industry's affairs dealing with legislative and regulatory matters.  For over 25 years I published articles defending our use of chemistry, and the way we use it.  Which meant I had to attack prominent scientists in and out of government.  Being the heterodox to an industry isn't the popular thing to do, and I wasn't popular.  But it was an adventure, and I wouldn't have changed one minute of that.

I will say this, with all the modesty I can possibly muster, which isn't much, I was right then and I'm still right, and that includes every position I've taken against junk science, whether it's been about chemistry, scientific testing, or all the lies and corruption surrounding Fauci and this false pandemic.  

I had a lot of friends in science before this pandemic hysteria, and what did bother me was in the beginning these science friends, who were always in agreement with me, ended up in opposition to my views on this false pandemic.   The mortality rate, the infection rate, and especially the vaccination mandates.  They were wrong!   Since I no longer correspond with them, I often wonder what must be going on in their minds as all the evidence has come out supporting my position.   

This brings me to the point at hand.  My friend Paul Driessen sends me articles he feels need to be shared as broadly as possible, which I happily publish.  Last week he sent this article, "Restoring trust in government by using the IQA",  by William L. Kovacs saying: 

The Federal government has left citizens living in information confusion, misinformation and conspiracy theories. Information clutter helps explain why only two in ten Americans trust Washington to do the right thing. But distinguishing between good and bad quality information should never be difficult when the information comes from our government. 

He went on to say the IQA was designed to generate trust from the public, but in point of fact, it's a toothless tiger.  From it's inception the government has failed, deliberately failed, to implement this law, and if they had, all the insane covid pandemic hysteria would have been stopped.  

When Paul sends me these article he usually prefaces with his comments:

The Information Quality Act defines government information as “any communication or representation of facts or data, in any medium or form.” It requires that government-disseminated information be accurate, useful and reproducible; that it have integrity; and that opinions be clearly identified as opinions, and not be disguised as facts. 

This seems logical, straightforward, and essential to the proper functioning of government and society. After all, if any of us lied or misrepresented salient facts to the government, we’d likely be fined or jailed. The same standards should certainly apply to government agencies and officials. 

The glaring problem is that federal government agencies have simply refused to abide by or follow the act’s clear and unequivocal mandates. Perhaps worse, federal courts have let them get away with this arrogant refusal to obey the law. The impacts on our health, welfare, jobs and economy should be obvious to anyone who has encountered the increasingly pervasive impacts of government on our lives.

Epidemiology alone isn't science because epidemiology is statistics and statistics alone cannot prove the existence or absence of risk.  Often these "statistics" epidemiologists spout out are nothing more than computer modeling.  That's how they come up with these insane predictions.  Also, mice aren't little people. The results of tests on laboratory animals do not necessarily pertain to humans. Mice aren't little rats either. Very often reactions to a substance that occur in mice do not occur in rats and vice versa.   

This has been the case forever.  In 2005 the America Council on Science and Health petitioned the EPA to stop declaring something was carcinogenic based solely on rodent testing. alone because that violated the principles outlined in the Information Quality Act.  They weren't opposed to rodent testing, but that's supposed the first step, not the final step in testing.  And certainly not the only step in declaring something carcinogenic.

Finally, after giving themselves extension after extension, five months later, the EPA replied with this dodge.  The EPA claimed:

".......their Risk Assessment Guidelines are not statements of scientific fact -- and thus not covered by the IQA -- but merely statements of EPA policy.”

One would think that any kind of risk assessment policy would be based on science, so if it isn't we must ask; just what are their policies based on?  We find this same cavalier attitude in every department of government and the federal judiciary, both of which need to be purged.  Starting by eliminating whole departments and agencies, including the EPA, and passing term limits for the federal judiciary. 

We absolutely know everything touted by Fauci and his followers was blatantly false.  How many lives could have been saved if someone in the federal government had one ounce of courage to put the nation, the people, and especially the children, ahead of themselves and these corrupt entrenched bureaucrats?

Now, who will answer?  When government officials deliberately ignore the laws of the land, and that malfeasance causes harm and damage, including deaths,  shouldn't they be held accountable?


Saturday, May 19, 2012

Understanding Risk

By Rich Kozlovich

Recently I spoke against an anti-pesticide ordinance at the April Cuyahoga County Council meeting in Cleveland, Ohio. The basis for this ordinance was that pesticides were “toxic” and “carcinogenic”. None of that is an explanation for understanding whether they represent an inappropriate ‘risk’ or not, and since those are both trigger words the ordinance was based on scare mongering. One of the council members claimed that they had the studies to show the health risks caused by pesticides. Baloney! If this was true then the EPA would be required by law to remove those products from the market place; and we need to understand that the EPA is not a pesticide friendly organization, but there are even limits to the kind of junk science they can heap on society. However, I do think it is important for everyone to know how risk evaluations are properly done, or in this case an explanation of how they are done improperly.

Statistics aren't science and cannot alone prove the existence or absence of risk. One of the problems with using statistics to determine risk is 'data dredging'. If you drag up enough data you can come up with any explanation that suits the particular issue you are trying to promote. “Statistics are being looked to more and more as explanations for answers to medical problems from people with expertise in mathematical manipulation and information technology, rather than from people with an understanding of disease and its causes." “Statics can’t prove cause and effect associations because they don’t provide biological explanations. Without such explanations, statistical associations are hollow numbers.” Biological explanations, not mere possibilities or conjecture, are a necessary component of determining the existence of risk.

Epidemiology alone isn't science because epidemiology is statistics and alone cannot prove the existence or absence of risk. Mice aren't little people. The results of tests on laboratory animals do not necessarily pertain to humans. Mice aren't little rats either. Very often reactions to a substance that occur in mice do not occur in rats and vice versa. The American Council on Science and Health petitioned the EPA to stop declaring substances ‘carcinogenic’ on rodent testing alone because that violated the principles outlined in the Information Quality Act. “Finally….EPA replied with a dodge, claiming that their Risk Assessment Guidelines are not statements of scientific fact -- and thus not covered by the IQA -- but merely statements of EPA policy.” One would think that policy would be based on science, so if it isn't we must ask; just what is this policy based on? So if the EPA can't find a reason to remove these products from the market place we can be assured some local council has nothing to offer that could ever begin to look like 'valid science'.

Exposure isn't toxicity. Just because someone is exposed to a substance or condition doesn't necessarily mean that they've been exposed to a harmful level. I often read that articles that deal with bio-monitoring to see just how many synthetic chemicals we have in bodies. That number has consistently been over 200. We are also living longer and healthier lives. Does that mean that having more synthetic chemicals in our bodies increases our life span and quality of health? The dose makes the poison. All substances are poisons in sufficient amount. Below that amount, exposures are not harmful. At some point the molecular load of any substance will be so small that cells will not respond to it. This is called the threshold principle.

There is always a safe exposure to a substance or condition.

Sources:

  1. Junk Science Judo, by Steve Milloy
  2. We Should Expect More from the EPA
  3. Toxic Substances Control Act (TSCA) Amendment Signed
  4. Ecological Sanity, by Claus and Bolander

Monday, May 10, 2010

The Alar Story

By Rich Kozlovich


The Alar story is a most enlightening account of how abuse of bureaucratic power, scare mongering by the media, and self enrichment by the green activists can create a real mess. If you ask most people who are somewhat familiar with this story how it all got started they will tell you that it was the 60 Minutes broadcast that did it. That is inaccurate; although the 60 Minutes segment set the story on fire, if you dig deeply into the whole Alar story you find that it takes so many twists and turns that it is hard to believe; but this is how the whole thing started.

In 1982 the EPA got caught up in a superfund scandal. By March of 1983 EPA Administrator Anne Gorsuch Burford resigned after finding herself in a bureaucratic mess between the EPA and the Department of Justice in an attempt to deal with this scandal. One prominent EPA staffer was fired and others left.

What has this to do with Alar? Everything! Because of the black eye EPA received over this it was decided that something had to be done to restore their credibility to the public. So what did they do? They felt that they needed to ban something, and since anti-pesticide activists love anyone who wants to ban something, they started looking around and viola; Alar was to be the target.

Why Alar? It had been used successfully as a growth regulator to keep apples from falling off trees since 1963. In 1983 the EPA placed Alar under “special review” and in 1984 they claimed that Alar was a potential carcinogen for children because after administering massive doses of Alar to mice tests showed that that it might cause cancer. It might be noted that rodent testing as a determinate as to what is carcinogenic has come under attack from the scientific community. Although critics of this procedure don’t disavow the value of using rodent testing, they dismiss the idea that EPA should be determining what is carcinogenic based on rodent testing alone.

On August 23, 2005 the American Council on Science and Health petitioned the EPA to “eliminate "junk science" from the process by which it determines whether a substance is likely to cause cancer in humans” under the Information Quality Act (IQA), which requires the government to use the best science available. Nearly five months later the EPA responded by “claiming that their Risk Assessment Guidelines are not statements of scientific fact -- and thus not covered by the IQA -- but merely statements of EPA policy.” If their policy guidelines aren’t based on scientific fact, what are they based on? What were they based on in 1985?

The reality is that in 1985 the EPA own “Scientific Advisory Panel” concluded that the laboratory animal studies of Alar were too flawed to use.” However, the anti-chemical people became involved to “help” EPA to ban Alar, because no matter how much they studied the matter EPA couldn’t develop enough evidence to justify banning Alar.

Eventually facts and studies were irrelevant. The NRDC, through Fenton Communications, a public relations firm that seems to specialize in representing radical environmental groups, approached 60 Minutes with this unwarranted health scare.

“Following the release of a report called “Intolerable Risk” — which claimed that Alar was “the most potent cancer-causing agent in our food supply” and blamed the chemical for “as many as 5,300” childhood cancer cases — Fenton and NRDC went on a five-month media blitz. The campaign kicked off with a CBS 60 Minutes feature seen by over 50 million Americans. Despite the fact that the claims were completely unfounded, hysteria set in. Apples were pulled off of grocery shelves, schools stopped serving them at lunch, and apple growers nationwide lost over $250 million.”

However, “from the standpoint of the NRDC and Fenton Communications, the campaign against Alar had been a phenomenal success. The public had been panicked, the product had been destroyed, and a major media organization, 60 minutes, had been a willing tool in carrying out the operation. Further, membership and contributions to the NRDC increased.” Worse yet, “after the election of President Clinton, the EPA ceased being an unwitting participant in the toxic scare campaign.”

“The Wall Street Journal printed one of David Fenton’s internal memos, after the Alar-on-apples scandal was publicly debunked. Here’s Fenton in his own words: “We designed [the Alar Campaign] so that revenue would flow back to the Natural Resources Defense Council from the public, and we sold this book about pesticides through a 900 number and the Donahue show. And to date there has been $700,000 in net revenue from it.”

Dr. Elizabeth Whelan states that “the Alar scare was totally without scientific merit. By the early 1990s, authorities ranging from the World Health Organization to U. S. surgeon general C. Everett Koop confirmed that there was never any health risk posed by the use of Alar. Even the late Don Hewitt, creator of 60 Minutes, told me that he regretted having done the Alar segment, but Ed Bradley, the producer of the piece, refused to retract it.”


When junk science becomes policy it is because the policy was already a conclusion in search of data. And when there is no data available… then apparently any old conclusion will do.