Situated Expert Judgement
QSAR Models and Transparency in the European Regulation of Chemicals
In this paper we discuss the kind of expert judgement demanded by the development of a particular class of models known as “Quantitative Structure-Activities Relationship” (QSAR) models, used to predict the toxicity of chemical substances, for regulatory and other purposes. We analyse the production of these models, and attempts at standardizing them. We show that neither a technical nor a procedural standardization is possible. As a consequence, QSAR models cannot ground a production of knowledge along the lines of “mechanical objectivity” or “regulatory objectivity”. Instead, QSAR models imply that expert judgement is situated, re-worked for each new case, and implies an active intervention of the individual expert. This has important consequences for risk governance based on models. It makes transparency a central concern. It also means that new asymmetries emerge, between companies developing sophisticated models and individual experts in regulatory agencies in charge of assessing these models.
Aykut, S., Benbouzid, B. and Demortain, D., “Foreknowledge in Public Policy. Towards a Political Sociology of Predictive Expertise — Introduction to the Special Issue”, Science & Technology Studies, this issue. Result score too low
Boullier H (2016) Autoriser pour interdire. La fabrique des savoirs sur les molécules et leurs risques dans le règlement européen REACH. Thèse pour le doctorat de sociologie. Université Paris-Est Marne-la-Vallée.
Boullier H., Demortain D. and Zeeman M. (2019), “Inventing Prediction for Regulation: Modelling Structure-Activity Relationships at the US Environmental Protection Agency”, Science & Technology Studies, this issue. Result score too low
Cambrosio A and Keating P (2009) Biomedical Conventions and Regulatory Objectivity. A Few Introductory Remarks. Social Studies of Science, 39(5): 651-664.
Cambrosio A, Keating P, Schlicha T and Weisza G (2006) Regulatory objectivity and the generation and management of evidence in medicine. Social Science & Medicine, 63: 189–199.
Daston L and Galison P (2007) Objectivity. New-York: Zone books. Result score too low
Demortain D (2009) Legitimation by standards: Transnational experts, the European Commission and regulation of novel foods. Sociologie du Travail 51:2, 104-116.
ECHA (2008) Guidance on information requirements and chemical safety assessment. Chapter R.6: QSARs and grouping of chemicals. European Chemical Agency. Result score too low
ECHA (2011) The OECD QSAR toolbox for grouping chemicals into categories. European Chemical Agency. ECHA-11-L-08-EN. Result score too low
Edwards P N (1999) Global climate science, uncertainty and politics: Data-laden models, model-filtered data. Science as Culture, 8(4): 437-472.
Edwards P N (2010) A vast machine: Computer models, climate data, and the politics of global warming. Cambridge (MA): MIT Press, 2010.
European Commission (2006) Regulation (EC) n° 1907/2006 of 18 December 2006 Concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Consolidated version of 1 June 2015, doc. 2006R1907. Luxembourg: Publications Office of the European Union.
European Commission (2016) Better Regulation: Delivering better results for a stronger Union. Communication from the Commission to the European Parliament, the European Council and the Council. COM(2016) 615 final. Result score too low
Fisher E, Pascual P and Wagner W (2010). Understanding environmental models in their legal and regulatory context. Journal of Environmental Law 22(2): 251–283.
Gramatica P (2007) Principles of QSAR models validation: internal and external. Molecular informatics, 26(5): 694-701.
Heaphy L (2015) The role of climate models in adaptation decision-making: the case of the UK climate projections 2009. European Journal for Philosophy of Science 5(2): 233-257.
Hilgartner S (2002) Science on Stage. Expert Advice as Public Drama. Stanford: Stanford University Press.
Jasanoff S (1990) The Fifth Branch. Science Advisers as Policymakers. Cambridge (MA): Harvard University Press. Result score too low
Jasanoff S (2004) States of Knowledge. Cambridge (MA), MIT Press. Result score too low
Jasanoff S (2005) Judgment Under Siege: The Three-Body Problem of Expert Legitimacy. In: Maasen S., Weingart P. (eds) Democratization of Expertise? Sociology of the Sciences Yearbook, vol 24. Springer, Dordrecht
Jasanoff S (2011) The practices of objectivity in regulatory science. In: Carnic C, Gross N, Result score too low
Latour B (1987) Science in action: How to follow scientists and engineers through society. Cambridge (MA), Harvard university press.
Laurent B (2017) Democratic experiments. Problematizing nanotechnology and democracy in Europe and the United States. Cambridge (MA): MIT Press.
Lavecchia A (2015) Machine-learning approaches in drug discovery: methods and applications. Drug Discovery Today 20 (3): 318–31.
Lo Piparo E and Worth A (2010) Review of QSAR Models and Software Tools for predicting Developmental and Reproductive Toxicity. JRC scientific and technical reports EUR 24522 EN. Result score too low
MacKenzie D (1993) Inventing Accuracy. A Historical Sociology of Nuclear Missile Guidance. Cambridge (MA): MIT Press. Result score too low
OECD (2007) Guidance document on the validation of (quantitative) structure-activity relationships [(Q)SAR] models. OECD, ENV/JM/MONO(2007)2. Result score too low
Salzman J (2005) Decentralized administrative law in the Organization for Economic Cooperation and Development. Law and Contemporary Problems, 68: 3-4. Result score too low
Saurugger S (2002) L'expertise: un mode de participation des groupes d'intérêt au processus décisionnel communautaire. Revue française de science politique, 4:52, 375-401.
Thoreau F (2016) 'A mechanistic interpretation, if possible': How does predictive modelling causality affect the regulation of chemicals? Big Data & Society, July-December: 1-11.
Vos E (2000) EU food safety regulation in the aftermath of the BSE crisis. Journal of Consumer Policy, 23:3, 227-255.
Wickson F and Wynne B (2012) The anglerfish deception. The light of proposed reform in the regulation of GM crops hides underlying problems in EU science and governance. EMBO reports, 13, 100-105.
Worth A, Hartung T and CJ Van Leeuwen (2004) The role of ECVAM in the validation of QSARs. SAR and QSAR in Environmental Research 15:5–6, 345–358.
Worth A et al. (2007) The role of the European Chemicals Bureau in promoting the regulatory use of (Q)SAR methods. SAR and QSAR in Environmental Research, 18:1-2, 111-125.
This Science & Technology Studies website ("Site") is owned and operated by The Finnish Society for Science and Technology Studies (“Society”), PO Box 117, c/o Otto Auranen, Sepänkatu 4-8 A 16, 33230 Tampere,Finland. The Finnish Society for Science and Technology Studies and its publication Science & Technology Studies are non-profit organizations.
The Society reserves the right to change, modify, add or remove portions of these Terms and Conditions at its discretion at any time and without prior notice. Please check this page periodically for any modifications. Your continued use of this Site following the posting of any changes will mean that you have accepted the changes.Copyrights and Limitations on Use
All content in this Site, including site layout, design, images, text and other information (collectively, the "Content") is the property of The Finnish Society for Science and Technology Studies/Science & Technology Studies and is protected by copyright and other intellectual property laws, unless otherwise noted.
You may not copy, display, distribute, modify, publish, reproduce, store, transmit, create derivative works from, or sell or license all or any part of the Content, products or services obtained from this Site in any medium to anyone, except as otherwise expressly permitted under applicable law or as described in these Terms and Conditions or relevant license or subscriber agreement.
You may print or download Content from the Site for academic, your own personal, non-commercial use, provided that you keep intact all copyright and other proprietary notices. You may not engage in systematic retrieval of Content from the Site to create or compile, directly or indirectly, a collection, compilation, database or directory without prior written permission from Science & Technology Studies.
The Site may contain robot exclusion headers, and by using the Site you agree that you will not use any robots, spiders, crawlers or other automated downloading programs or devices to access, search, index, monitor or copy any Content. The harvesting of postal or email addresses from the Site for purposes of sending unsolicited or unauthorized commercial material, is prohibited. Any questions about whether a particular use is authorized and any requests for permission to publish, reproduce, distribute, display or make derivative works from any Content should be directed to the Science & Technology Studies Assistant Editor.
You may not use the services on the Site to publish or distribute any information (including software or other content) that is illegal; violates or infringes upon the rights of any other person; is abusive, hateful, profane, pornographic, threatening or vulgar; contains errors, viruses or other harmful components; or is otherwise actionable by law. Science & Technology Studies may at any time exercise editorial control over the content of any information or material that is submitted or distributed through its facilities and/or services.
You may not, without the approval of Science & Technology Studies, use the Site to publish or distribute any advertising, promotional material, or solicitation to other users of the Site to use any goods or services. For example (but without limitation), you may not use the Site to conduct any business, to solicit the performance of any activity that is prohibited by law, or to solicit other users to become subscribers of other information services. Similarly, you may not use the Site to download and redistribute public information or shareware for personal gain or use the facilities and/or services to distribute multiple copies of public domain information or shareware.Trademarks
All trademarks appearing on this Site are the property of their respective owners.Links to Other Sites
The Site may contain hyperlinks to other sites or resources that are provided solely for your convenience. Science & Technology Studies is not responsible for the availability of external sites or resources linked to the Site, and does not endorse and is not responsible or liable for any content, advertising, products or other materials on or available from such sites or resources. Transactions that occur between you and any third party are strictly between you and the third party and are not the responsibility of Science & Technology Studies. Due to the fact that Science & Technology Studies is not responsible for the availability or accuracy of these outside resources or their contents, you should review the terms and conditions and privacy policies of these linked sites, as their policies may differ from ours.
Last revised: 10 October 2012