Letter on John Graham

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Citizens for Sensible Safeguards

May 15, 2001

The Honorable Fred Thompson
Chairman
Committee on Governmental Affairs
United States Senate
Washington, D.C. 20510

Dear Mr. Chairman:

As chairman of Citizens for Sensible Safeguards – a broad-based coalition of more than 200 public interest organizations – I am writing to express our outrage that you have refused to allow witnesses at John Graham’s confirmation hearing, despite receiving a number of requests from interested parties wishing to express their views.

Dr. Graham’s nomination is opposed by environmental organizations, labor unions, public health and consumer groups, as well as a host of academics, including 11 from Harvard Medical School and the Harvard School of Public Health (where Dr. Graham’s Center for Risk Analysis resides). The Committee and the public deserve to hear why.

Some very serious questions have been raised about Dr. Graham and his analytical methods. For example:

Dr. Graham’s Center is heavily funded by a vast array of corporate interests, which he has routinely helped in holding off new regulation. As administrator of OMB’s Office of Information and Regulatory Affairs (OIRA), Dr. Graham will be in the position to reject regulations affecting these former benefactors. How will this potential conflict of interest affect his ability to be an objective and fair evaluator of agency rulemakings?
In advocating regulatory reforms, Dr. Graham has testified before the Committee that we could save 60,000 additional lives at no additional cost if we shift resources from wasteful programs to cost-effective programs. This study, however, is mostly based on “regulations” that were never actually implemented – as pointed out in a recent critique by Lisa Heinzerling, professor at Georgetown Law Center – and thus tells us virtually nothing about our real-world system. Yet Senators clearly understood Dr. Graham to mean existing regulatory programs. Did Dr. Graham mislead the Committee, as well as the public, to promote his views on regulatory reform?
Dr. Graham has used questionable analytical practices in critiquing government regulation, which he will be in position to implement as OIRA administrator. These practices have had the inevitable effect of deflating benefits relative to costs. The Committee needs to better understand what underlies this analysis. Are Dr. Graham’s analytical assumptions inappropriately slanted to make most regulation appear cost-ineffective?

Unfortunately, without witnesses, these questions cannot be examined fully. During Sen. Roth’s tenure as chairman of this Committee, he allowed witnesses to testify on a number of controversial nominees (perhaps most notably James Miller, President Reagan’s nominee to head the Office of Management and Budget). This approach allows for an open, public exchange of ideas in which members are able to probe various experts and arrive at a considered judgment.

OIRA is an extremely powerful office, with the responsibility to approve or reject agency rules. The administrator should have the credibility and objectivity to make crucial decisions regarding health, safety, and environmental protections. Accordingly, this Committee should take the time to carefully examine whether Dr. Graham is the right person for the job. By denying witnesses, you have denied such a thorough examination.

Sincerely,

Gary D. Bass
Executive Director
OMB Watch