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SCIENTISTS, ENGINEERS, AND THE BURDENS OF OCCUPATIONAL EXPOSURE: 75 THE CASE OF THE LEAD STANDARD original typesetting files. Page breaks are true to the original; line lengths, word breaks, heading styles, and other typesetting-specific formatting, however, cannot be About this PDF file: This new digital representation of the original work has been recomposed from XML files created from the original paper book, not from the retained, and some typographic errors may have been accidentally inserted. Please use the print version of this publication as the authoritative version for attribution. CONCLUSIONS In its evaluation of the efforts of both EPA and OSHA to regulate exposure to lead, the National Research Council has underscored the extent to which regulatory agencies faced with politically contested alternatives have at times sought to justify their actions by reliance on the protective mantle of value-free science (National Research Council, 1980). Although OSHA explicitly acknowledged that it could not wait for the resolution of the full range of scientific controversies surrounding the health effects of lead before issuing its standard, it did seek to ground its much-disputed limit on exposure to lead in air on a mathematical model. For the National Research Council, however, "The data base that supported [both the EPA and OSHA] models was small, and neither the exact form of the mathematical function nor the slope of the resulting curve [could] be determined with great accuracy" (National Research Council, 1980, p. 213). That OSHA had sought to provide a scientifically objective basis for its policy determinations should come as no surprise. Like other regulatory bodies, either because of demands placed upon them or because of the ideological commitments of the scientists upon whom they rely, OSHA must adopt a posture in which the tasks of hazard evaluation and risk assessment are viewed as above politics and the influence of social values. The controversy surrounding regulation of lead demonstrates, however, that even the putatively technical tasks of hazard evaluation and risk assessment inevitably involve judgments that are social and moral. As a consequence, they, as much as the more explicitly political tasks of risk management and regulation, must be judged within a broad ethical framework that has at its core the issue of distributive justice. Thus, the widely read report of the National Research Council Committee on the Institutional Means for the Assessment of Risks to Public Health, Risk Assessment in the Federal Government: Managing the Process, which attempts to draw a sharp distinction between the value-free task of risk assessment and the value-laden task of policymaking, must be viewed as flawed and as an oversimplification. Because scientists, engineers, and other professionals are asked to make determinations on the basis of data that are of highly variable quality with often ambiguous implications for policy and regulation, it is inevitable that the interpretations will be affected by social and political interests (Crandall and Lave, 1981). In the struggle over adoption of a lead standard, scientists confronted each other as partisans. For some, this was an unseemly encounter. If the perspective presented in this paper is correct, however, such conflicts must be viewed as unavoidable. Indeed, efforts to eliminate them can result only in a process of obfuscationâone in which social values and interests will be masked.
