Open Letter to Nature

Peter Wood

Nature just published a letter by Naomi Oreskes that condemns Secretary Pruitt's proposed rule to require reproducibility in some science used by the Environmental Protection Agency in its rulemaking. Professor Oreskes' letter mentions the National Association of Scholars (NAS) and President Peter Wood specifically in the catalogue of organizations she opposes. Peter Wood has sent in the following reply to the Correspondence column of Nature. We hope they will publish it; in the meanwhile, we post the reply here.


Naomi Oreskes writes that the irreproducibility crisis is real, but that “the greatest concerns among scientists over reproducibility relate to biomedicine and psychology.” It would be more correct to say that scientists in biomedicine and psychology have proceeded further in scrutinizing their own disciplines and beginning to take corrective measures. She also seems to believe that government regulations should take no cognizance of the ever-widening professional awareness of the failure of large amounts of research to reproduce. This non sequitur gains no credibility even if it is shared by the editors of Nature, the Proceedings of the National Academy of Sciences, and Science. The National Association of Scholars (NAS) indeed believes that Secretary Pruitt’s proposed rule Strengthening Transparency in Public Science is a justified response to the irreproducibility crisis, which continues and strengthens the American government’s longstanding concern to base policy on the best available science. We have provided a public comment explaining our rationale.

We further suggest in our public comment that the Environmental Protection Agency (EPA) draft a Reproducible Regulatory Science Guidance Document (RRSGD) to govern all EPA administrative processes. This RRSGD should define “best available science” to include only scientific research done using pre-registered protocols, whose research data, associated protocols, computer codes, recorded factual materials, and statistical analyses are archived and publicly available in a manner sufficient for continuing independent verification. The RRSGD should also explicitly rescind the “weight of evidence” standard for justifying regulatory policy, and replace it with a “best available reproducible science” (BARS) standard, which meets the above definition of “best available standard.” The NAS urges the scientific community to support these needed reforms to government policy, and to reject the evasions proffered by political activists who claim to speak for science while rejecting all practical measures to guarantee the touchstone of science—reproducibility.


Peter Wood


National Association of Scholars


Image Credit: Andreas E. Neuhold, Public Domain

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