Essay on Deconstruction Analysis of an Environmental Policy Claim

The Claim

In 2017, the Trump Administration's Environmental Protection Agency (EPA) overturned the ban on the use of chlorpyrifos, which was its own proposed decision two years before. In 2014, EPA revised the human health risk assessment of chlorpyrifos and offered evidence on the harmful effects of this pesticide on children's health. Based on these findings, in 2015, EPA proposed to revoke all tolerances for chlorpyrifos and cancel all registrations for it since 'the agency is unable to conclude that the risk from aggregate exposure from the use of chlorpyrifos meets the safety standard of section 408(b)(2) of the Federal Food, Drug, and Cosmetic Act (FFDCA).' At this time, this environmental policy seemed to be viable and reasonable since chlorpyrifos is a toxic nerve agent pesticide that is proven to impair brain development in children, damage cognitive function among adults, and harm the environment and wildlife. Under the FFDCA, EPA is responsible for establishing maximum residue limits on food items. Since Trump assumed office in 2017, EPA has been blamed for supporting the harmful decisions of the new administration.

In response to the EPA's decision to overturn the ban on chlorpyrifos, the American Association of Pediatrics (AAP), whose mission is to 'attain optimal physical, mental, and social health and well-being for all infants, children, adolescents, and young adults,' and the EPA scientists disagreed with the proposal of EPA's leadership. AAP supported the ban, stating that 'EPA has no basis to allow continued use of chlorpyrifos, and its insistence on doing so puts all children at risk.' Meanwhile, the EPA scientists disagreed with the leadership's decision to allow the use of chlorpyrifos on fruits, vegetables, nuts, and crops since they have been studying this pesticide for decades and have found its potential to cause harm to children and young adults. Regardless of resistance, EPA Administrator, Scott Pruitt, claimed that 'By reversing the previous administration's steps to ban one of the most widely used pesticides in the world, we are returning to using sound science in decision-making - rather than predetermined results.' Pruitt's claim is intended to show that using chlorpyrifos in agriculture is not a serious environmental problem that is not in need of a solution. Since there are a lot of opposing perspectives to the 2017 decision of EPA, deconstructing Scott Pruitt's claim to identify hidden bias, advocacy over the inquiry, incomplete claims, quality of evidence, and the presence of systems thinking is critical to determine the credibility of the claim.

Where to Begin

Examining my own bias is necessary for beginning the deconstruction analysis of EPA's claim. As a person who is deeply concerned with the protection of the environment, I believe that chlorpyrifos should be banned from use at least across the United States since it harms not only the environment and wildlife but also has an adverse effect on the brain development of children and young adults. I was drawn to EPA's claim about the overturn of the ban on chlorpyrifos due to my distrust of the current President's Administration. The author of the claim, Scott Pruitt, is an experienced American lawyer and Republican politician who served as the EPA Administrator from 2017 to 2018 and was nominated by Trump. Before that, Scott Pruitt occupied such important positions as Attorney General of Oklahoma and the Republican Attorneys General Association; that is why he should have been regarded as competent in environmental initiatives and law.

However, his reputation tells about the opposite since he is known for being corrupt and destroying the foundations of EPA by 'firing scientists and replacing them with industry lobbyists; undoing critical regulations that protect our air and water; and favoring industry interests over public health.' There is a clear mismatch between Scott Pruitt's expertise and claim because after occupying such important posts and enacting regulations, he said that the use of chlorpyrifos in agriculture is sound science. Thus, Scott Pruitt's argument is a clear example of support for the Trump administration's reversed course on banning chlorpyrifos and advocacy against the findings of EPA scientists and AAP about the harmful effects of the chemical on the environment, wildlife, and human health.

Who Can You Trust?

In reviewing EPA’s claim for potential bias, it is necessary to assess the author’s interest in the topic. Mr. Pruitt is a strong supporter of the Trump Administration and is close to industry lobbyists; thus, he can be interested in “making policy decisions to boost profits and prevent regulation, often at the expense of the health and well-being of citizens and the environment.” He served as the EPA Administrator only for one year and has been blamed for numerous misconducts regarding environmental laws. In addition to that, Mr. Pruiit’s decision was not justified in the claim since he relied on general phrases and criticism against the Obama administration that banned chlorpyrifos in 2015 based on finding potential harms. Therefore, Mr. Pruitt seems to have a one-sided ideological perspective that is conducive to biased positions and may not genuinely be an expert on the effects of chlorpyrifos on the environment, wildlife, and children’s health.

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Does the Structure of the Claim Justify Conclusion?

A type of analytical structure of the claim can say much about its completeness indeed. The author did not justify his claim regarding the allowed use of chlorpyrifos in agriculture and did not back up his claim with research findings or opinions of EPA scientists. In fact, it seems at least illogical to make a decision to allow the use of chlorpyrifos across the United States if EPA researchers' studies have found that it has had a negative impact on the environment, including drinking water, crops, and air. No other person or organization supported Mr. Pruitt's decision. Instead, the EPA scientists, AAP, initiators of a Chesapeake Bay Program, and the National Marine Fisheries Service all advocate against the use of this chemical in agriculture since it contaminated drinking water, crops, and air near treated fields.

The first part of the claim seems to criticize the regulation of the Obama administration rather than provide a sound decision. Mr. Pruitt relies on the fact that chlorpyrifos is a widely used chemical all around the world and calls this trend a sound science. In reality, the studies show that chlorpyrifos has harmful ecological effects. Thus, Scott Pruitt's claim cannot be considered a common-sense environmental policy because it goes against sound science, is not grounded in scientific principles, and looks like advocacy for agricultural producers and pesticide manufacturers, who are the primary stakeholder of this decision and potential winners. The decision would not have a significant economic impact on small businesses since EPA has determined that 'less than 39,000 of the 1.2 million small farms nationwide, or approximately 3% of all small farms, may be impacted by this proposed revocation.' However, the general public does not trust EPA's reports since there is an opinion that the American company Dow Chemical influenced the EPA to make such a decision by giving '$1 million to fund President Trump's inaugural activities.' Meanwhile, environmentalists are potential losers who would have to cope with the policy's implications. Hence, the structure of the claim does not justify the conclusion.

Does the Evidence Support Conclusion?

Completeness, currency, and credibility of the evidence are challenged within this claim since the author presented no real proof that chlorpyrifos is not harmful to the environment. The EPA’s own scientists found “no level of chlorpyrifos in food and water that can be considered safe” and recommended to terminate all agricultural use of the chemical. Meanwhile, Mr. Pruitt draws from the fact that chlorpyrifos is one of the most widely-used pesticides in food crop agriculture. A Union of Concerned Scientists for a Healthy Planet and Safer Word stated that EPA ignored the scientific evidence on chlorpyrifos and called Mr. Pruitt’s decision politically motivated. In reality, chlorpyrifos contaminates air, water, and food, reduces the spawning productivity of adult and juvenile Atlantic sturgeon, and impacts the brain development of children and young adults. Thus, the author of the claim missed an opportunity to present some evidence of the beneficial use of chlorpyrifos in food crop agriculture.

Does the Claim Show Multidisciplinary Systems Think?

When applying a holistic, systems thinking approach, it becomes clear that Mr. Pruitt’s claim is unreasonable and unjustified. Sound science, which the author mentions in his claim, shows the opposite to the claim because the EPA’s own scientists found that chlorpyrifos is not only harmful to the environment but also impacts other systems such as air and water pollution, human health, and food contamination. What is apparent within this claim is that Mr. Pruitt criticizes the Obama administration’s policies and favors pesticide manufacturers, taking care of their economic growth.

Vague language is used in the claim, including a statement that the decision to overturn a ban was made using sound science. It does not explain what studies or research findings the author meant or what positive impact of the pesticide anybody could find. In addition to that, EPA has never concluded that the commercial use of chlorpyrifos meets the safety standard of section 408(b)(2) of FFDCA since this decision ignored genetic evidence of vulnerable populations, endocrine-disrupting effects, and data regarding cancer risks. Thus, the claim does not show multidisciplinary systems thinking in its nature.

Conclusion

As a result of deconstructing the former EPA Administrator Scott Pruitt's claim that 'By reversing the previous administration's steps to ban one of the most widely used pesticides in the world, we are returning to using sound science in decision-making - rather than predetermined results,' many weaknesses in the author's approach have been identified. It is apparent that Mr. Pruitt does not have a deep understanding of the effect of chlorpyrifos on the environment, wildlife, and human health even though he served as the EPA Administrator for one year. He failed to consider the EPA's own scientists' findings when making his claim. As it often occurs, environmental policy-making has appeared to be vulnerable to political impacts since Mr. Pruitt's decision was not justified but rather politically motivated. If Mr. Pruitt had backed up his assertion with scientific evidence, it could have been a more defensible and credible claim.