In their article, In Defense of Regulatory Peer Review, J.B. Ruhl and James Salzman have made a valuable contribution to the politically charged debate over regulatory peer review. Their proposal for a mechanism to provide empirical data about whether agencies would benefit from peer review helps lift the debate from the realm of arguing over "sound science." They correctly identify the need for information collection to determine the scope of the problem before proposing the notion that regulatory peer review is the solution.

It hardly seems controversial to suggest that research used for regulatory decisionmaking be peer-reviewed, but the devil is always in the details. For 25 years, the nonprofit organization OMB Watch has tracked and documented increasingly prescriptive executive branch policies over agency regulatory decisions. 2 These policies have marginalized and/or reduced the importance of science (and social considerations) in agency decisionmaking in favor of economic considerations, culminating in today's open attacks on science: disputing and falsifying scientific evidence; introducing scientific "uncertainty" as justification for avoiding or delaying rulemakings; delaying or suppressing scientific findings; and censoring and intimidating government scientists.