SCIENTIFIC CREDIBILITY OF GOVERNMENT PUBLIC HEALTH ADVISORY COMMITTEES

Resolution 123-03

Author: Robert M. Gould, MD

Adopted March 25, 2003

Whereas, a wide variety of federal government agencies with jurisdiction over public health, as well as state and local public health agencies, routinely engage scientific advisory committees and other similar bodies to furnish expert advice, ideas, recommendations, and diverse opinions to guide agency policy and decision-making; and,

Whereas, these committees are a core component in ensuring that the best science is brought to bear to protect the publicís health, underscoring the importance that members of such scientific and public health advisory committees be the most qualified scientists and experts in their fields; and,

Whereas, it is standard ethical practice that candidates for service on scientific and public health advisory committees should be free of direct financial conflicts of interest, and that all such conflicts of interest should be disclosed to health agencies and the public, so that they can be examined carefully for potentially disqualifying biases; and,

Whereas, the Federal Advisory Committee Act (FACA) states that federal advisory committees must be fairly balanced in terms of the points of view represented,[1] and that such committees must not be inappropriately influenced by the appointing authority or by any special interest;[2] and,

Whereas, there are currently no uniform criteria for determining and managing conflicts of interest or achieving balance on federal scientific and public health advisory committees, or for determining the scientific or expert qualifications of candidates for such committees, and there are also no such standards for committees at the state and local level; and,

Whereas, federal government officials have recently taken steps to restructure key scientific and public health advisory committees by retiring the committees before their work is completed, removing or failing to reappoint qualified members and replacing them with less scientifically qualified candidates and candidates with a clear conflict of interest, and focusing on the political and ideological leanings of potential panelists rather than their scientific qualifications, actions that suggest an effort to inappropriately influence these committees;[3,4,5] and,

Whereas, in particular, four panels—the Centers for Disease Control and Prevention’s (CDC) Advisory Committee to the Director of the National Center for Environmental Health (NCEH), CDC’s Advisory Committee on Childhood Lead Poisoning Prevention (ACCLPP), the Food and Drug Administration’s Reproductive Health Drugs Advisory Committee, and the DHHS’s National Human Research Protections Advisory Committee (NHRPAC)óare among the most recent and egregious examples of this effort, which may lead to decreased federal protections for women, children, and other vulnerable groups;[6,7,8,9] therefore be it

RESOLVED: That CMA calls on government officials at all levels to closely follow the existing guidelines set forth in the Federal Advisory Committee Act pertaining to the membership on scientific and public health advisory committees and to develop more specific criteria related to scientific expertise, financial disclosure, conflict of interest and diversity; and be it further

RESOLVED: That CMA should refer this issue for national action.

References

1 Federal Advisory Committee Act, 5 U.S.C. Appendix 2, ß5(b)(2)

2 Federal Advisory Committee Act, 5 U.S.C. Appendix 2, ß5(b)(3)

3 HHS Seeks Science Advice to Match Bush Views. Washington Post. September 17, 2002.

4 Bush's Science Advisors Drawing Criticism. New York Times. October 9, 2002.

5 Advisors Put Under a Microscope. Los Angeles Times. December 23, 2002.

6 Michaels, David et al. "Advice without Dissent." Science. Vol 298, p 703, October 25, 2002.

7 Ferber, Dan. "Critics See a Tilt in a CDC Science Panel." Science. Vol 297, p 1456-1457, August 30, 2002.

8 A Report by Markey, Edward J. (Rep D-MA). Turning Lead into Gold: How the Bush Administration is Poisoning the Lead Advisory Committee at the CDC. October 8, 2002.

9 "Keeping scientific advice non-partisan" (editorial). The Lancet. Vol 360, p 1525. November 16, 2002.