‘Science Based Policy’ is a sham
Policymakers interested in enacting science-based policy must first learn how to read scientific literature and understand scientific methodology. Otherwise the phrase becomes nothing more than a branding strategy, argues Ryan Khurana.
If EU regulators want to embody "science-based policy," they'll need to end disorder in their evidence first.
The term "science-based policy" has gained popularity this year as the March for Science drew international attention. The application of scientific research in policy making, however, leaves much to be desired. Science as a tool can only provide us answers, but the quality of those answers depends on asking the right questions. Unfortunately, not everyone does that. Thanks to special interest groups framing artful questions to policy-makers while lobbying, research gets distorted along the way. The end result? Poor public policy that isn't so scientific.
The EU's current Ecodesign Directive, a component of its clean energy strategy post-2020, represents just one of the examples in which asking the wrong questions has led to baffling policy conclusions. A policy intended to reduce environmental waste and improve public health may end up doing just the opposite. In order to avoid the consequences of poor policy, we need to properly frame the issues with sound science.
The most blatant example of this distortion is in the role of hand dryers in contributing to energy efficiency and public health. The preparatory study for the directive came to some pretty damning conclusions about the impact of hand dryers, comparing them negatively to paper towels in terms of hygiene, and making odd claims about the incentives to produce energy efficient hand drying technologies. The study researched some of the literature surrounding the effects of electric hand dryers, but off the bat excluded any research into the effects of paper towels, presenting clear bias for one of the products they intended to compare.
Further, it is claimed, without justification, that the regulations they intend to introduce are "clearly favourable to energy-efficient hand dryers [and] the implementation of Ecodesign requirements could rather help manufacturers to expand". These are strong conclusions to make without evidence to back them up, clearly going against the very principle of science-based policy that the study was meant to support.
The negative view of hand dryers that the study defends is a result of the narrow scope of studies consulted, with only four studies used to support their conclusions. It is paramount for sound, science-based policy to consult the whole body of research on a topic, and not just a select few.
Of the mere four studies consulted – all of which had negative conclusions on the hygiene of hand dryers – all had distorted testing methods. One of the studies had participants dip gloved hands into a solution filled with bacteria, and calculated how much the bacteria spread when drying. This is an absurd question to ask, and one that clearly biases the studies to support certain products over others. People do not use hand dryers when their hands are covered in germs; they use hand dryers after having just washed their hands. If anything, these studies show that people should be encouraged to wash their hands thoroughly, and reveal little about the use of hand dryers.
Dyson microbiologist Toby Saville referred to studies that used this approach "fundamentally flawed" and called into question the integrity of the scientists who conducted them. The most cited study in the consultation was funded by the European Tissue Symposium (ETS), a trade association representing paper towel makers. As businesses increasingly adopt hand dryers, which are in the long-run more cost efficient than paper towels in terms of upkeep, the ETS has a clear incentive to distort research on the topic when lobbying policymakers. The paper towel industry is presently five times the size of the hand dryer industry in Europe, but its market dominance continues to fade as dryer technology improves, and its costs fall.
A science-based policy approach should be aware of the biases present in studies they cite, which while not inherently invalidating their claims, require further investigation and independent study.
By encouraging additional independent research, the European Commission would find that the scientific support for their claims that hand dryers are unhygienic is sparse.. Research published in the "Journal of Microbiology" and another by the Mayo Clinic found no significant difference in the level of microorganisms after drying hands with warm air compared to paper towels. In 2009, an article in the Pharmaceutical Microbiology Forum reviewed several studies on paper towels versus air dryers and concluded that there was no solid evidence for claiming automatic dryers are unhygienic. HEPA filters, common to most modern hand dryers, have been shown to remove 99% of the bacteria dispersed from hands into the air, which further shows the technological developments that have improved hand dryer quality.
As with all scientific research, a healthy dose of skepticism leads to greater inquiries and produces sound results. A "science-based policy" means following that protocol and consulting large bodies of literature and critiqued methodologies. Citing one study with questionable methodology and crony roots simply isn't enough to be considered "science-based." In that regard, The Ecodesign Directive's preliminary consultation failed.
Policy makers interested in enacting science-based policy must learn how to read scientific literature and understand scientific methodology. Otherwise the phrase becomes nothing more than a branding strategy.
Ryan Khurana is a UK-based Research Fellow at the Consumer Choice Center.
