Conrad and Becker’s “10 Criteria” Fall Short of Addressing Conflicts of Interest in Chemical Safety Studies

In their review “Enhancing Credibility of Chemical Safety Studies: Emerging Consensus on Key Assessment Criteria”, Conrad and Becker (2011) proposed the application of 10 criteria to individual studies as a means of assessing a study’s “credibility.” They characterized the 10 criteria as an “emerging consensus” and “encouraging convergence” that can solve “this problem of legitimacy in chemical evaluation … regardless of its funding source.” Conrad and Becker explicitly excluded funding by industry as a criterion for evaluating studies, labeling funding-based criteria as “unscientific”; they also dismissed outright consideration of developing potentially unbiased, third-party mechanisms for chemical safety testing as “too costly and complicated.” We agree with Conrad and Becker that there is an urgent unmet need to address the problem of conflict of interest in the science that underlies the regulation of chemicals used in commerce. However, Conrad and Becker’s 10 criteria fall short of what is needed in several critical ways.