Toxic Rules: The Epistemic Consequences of Standardized Practices in Chemical Regulation

Toxic chemicals are all around us: in the food we eat, the water we drink, the air we breathe. Despite robust evidence demonstrating their myriad health and environmental consequences, regulatory action has been weak and slow. In this talk, I demonstrate why governments have failed to regulate chemicals widely considered toxic: because agencies including the U.S. Food and Drug Administration and Environmental Protection Agency have relied on partial knowledge, basing key decisions on industry studies. They do so not because of who makes the knowledge claims, but rather how they are made—namely, according to toxicity testing standards developed in the 1970s. Regulators across the industrialized world adopted these standards to make chemicals governable and facilitate international trade. The Organisation for Economic Co-operation and Development (OECD) played a central role, serving as the site where industrialized nations negotiated the scientific methods corporations and governments would use to evaluate toxicity. I demonstrate how, in determining these methods, OECD members prioritized economic concerns over epistemic ones, and argue that regulators’ reliance on the knowledge production practice of standardized protocols created an inability to know and act on knowledge produced by other means.