John D Graham (Doc. Index)

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This stub is a work-in-progress by the ScienceCorruption.com journalists's group. We are indexing the millions of documents stored at the San Francisco Uni's Legacy Tobacco Archive [1] With some entries you'll need to go to this site and type into the Search panel a (multi-digit) Bates number. You can search on names for other documents also.     Send any corrections or additions to editor@sciencecorruption.com

This article is part of the Tobacco portal on Sourcewatch funded from 2006 - 2009 by the American Legacy Foundation.

John D Graham ran the Harvard Center for Risk Analysis, and became a guru of conservative politics on questions of health and safety regulations during the presdency of George W Bush. Through its connections to Graham and the Harvard name, the HCRA, implied (but did not say outright) that it was connected to the Harvard School of Public Health. It was not -- the center was funded by large corporations with poisoning and polluting problems.



DISAMBIGUATION: Don't confuse him with another John D Graham, who was the chairman and CEO of Fleishman-Hillard public relations in the 2000-2001 period). Both worked extensively for the tobacco industry.

 



Public Citizen report on John D Graham
Ralph Nader's organization prepared a comprehensive document on John D Graham's activities at the time when President George W Bush elevated him to the prime position for corporate lobbying, by placing him in charge of the various regulatory agencies. He was therefore able to block Federal environmental, health and safety regulatory activities.

This is a must-read document, that is accurate as far as we can tell. http://legacy.library.ucsf.edu/tid/lnk22c00/pdf

Documents & Timeline

1978 /E The subjects of John D Graham's degrees are omitted from his resume on the HCRA Web site, but Graham has previously told Congress that both his undergraduate and master's degrees are in public policy. We called Wake Forest University, where Graham earned his bachelor's degree, and were told by staff in the alumni office that there is no undergraduate program in public policy and that, according to their records, Graham earned his B.A. in economics. Graham's doctorate from Carnegie Mellon is in a subset of public policy called "decision analysis."


1978 BA, Wake Forest University (economics and politics)


1980 MA, Duke University (public policy)


1983 PhD, Carnegie Mellon University (public policy)


1989 Jan 21 Joint meeting of the International Life Sciences Institute (+ Nutrition Foundation) (ILSI and ILSI-NF) at Paradise Island in the Bahamas. This organisation is run by global food, drug, chemical and energy corporation, with a primary interest in food processing.. They have ILSI divisions in North America, Europe, Latin America, Australia, and Japan The ILSI claims to have had independently-funded divisions: the "Health & Environmental Sciences Institute" (HESI); the Nutrition Foundation (NF); a "Risk Science Institute"(RSI); and a Research Foundation (RF).

The list of their recent activities included the headings "WHO and FAO" and they were focussing on regulatory matters and EC Harmonization (a euphemism for setting standards at the "lowest-common-denominator" across Europe.) They also decided at this meeting to establish a Worldwide Environmental Sciences Division "to provide a mechanism for companies from the chemical, petrochemical, pharmaceutical, automotive and other consumer product industries to address scientific issues of mutual interest."

The core controlling group of the ILSI had membership among the food, confectionary, beverage, chemical and phamaceuticals companies, plus some from the commercial research institutes, and universities. Coca Cola appears to have been the founder, and it had a number of prominent members (as did PepsiCo and Cadbury-Schweppes) (at an initial membership fee of $15,000 each + annual dues to be determined. (Total budget $2 million - it wanted a $10 million endowment) "Separate assessments will be made for technical committee membership and support of their activities." [Note: They paid extra to sit on these committees!] It also had a 'cooperative agreement' with the Environmental Protection Agency, and an association with the Brookings Institution. The ILSI also 'guided' the meetings of the Toxicology Forum. (Eventually the World Health Organisation banned ISLI participation in their activites.)

Alex Malaspina (from Coca Cola) was President; James W Stanley from Pepsi-Cola was on the board with representatives of confectionary giants Hershey, Mars (Masterfoods), Nestlé, Cadbury, Kellogs and General Foods, and Robert J Moolenaar of Dow Chemicals. This is the ILSI report of Malaspina's address.

In looking to the 90's and beyond, Dr. Malaspina indicated that we are faced with more time—and more money—being devoted to regulatory matters as a result of a new administration which is likely to be more aggressive in food regulation, increased government involvement, both at the federal and state level, and consumer activists who continue to question the relationship between diet and health and to challenge the safety of key food ingredients. ILSI is prepared to meet those challenges by continuing to generate scientific data to resolve pending issues, providing relevant scientific data to state agencies, and working to harmonize food regulations and facilitate international trade. A proposal will be presented to the ILSI Board of Trustees to establish a Division of Environmental Sciences within ILSI to concentrate on environmental chemical issues. This division will provide a mechanism for companies from the chemical and pharmaceutical industries to be members in ILSI while preserving ILSI-NF's concentration on issues of importance to the food industry. To support the long-term programs of the ILSI Risk Sciences Institute and ILSI Research Foundation, a fund raising campaign will begin in early 1989.

A total endowment of $40 million over the next 3-5 years is the ultimate fund-raising goal.

Such an endowment is essential if these programs are to have the stability and continuity essential to basic research and educational programs and if they are to be able to make the long-term commitments necessary to make a meaningful impact in an area.

John D Graham was associated through the Society of Risk Analysis, and had run a Seminar in June 89 on "New Directions for Air Toxics Legislation". The ILSI gave him a model for his Harvard operations. [2]

[Note the list of scientists to be invited to form the Risk Institute division of ILSI was drawn up with Tom Borelli from Philip Morris][3]

1990 Feb 19 - 21 John D Graham and Philip Morris's Mayada Logue (assistant to Tom Borelli at Science & Technology, PMUSA) first met at the Winter Toxicology Forum. He was listed at this time as an "Associate Professor, Harvard School of Public Health" she was listed as "Scientist, Philip Morris USA" in Richmond. [4]


1990 Dec 27 Graham has circulated a letter informing consultants and others of his plan (via the Center for Risk Analysis, at the Harvard School of Public Health) to peer review the U.S. Office of Management and Budget's (OMB) report on risk assessment in the Federal Government. He plans to hold a small workshop on the subject on March 6-7 1991.

That report has attracted a great deal of attention since it published the previous summer because it was highly critical of the manner in which risk assessments are conducted within the Federal Government. The Harvard School of Public Health viewed the OMB review as creating a major policy document of the Federal Government and set about to develop its own criticisms of the OMB report. [Note: See the letter on page 8] [5]

Graham is trying to enlist scientific lobbyist W Gary Flamm in support of a workshop to critically examine the OMB's methodology for federal government's risk assessment

The HCRA believes that risk assessment practice is likely to undergo significant change in the years ahead due to widespread recognition of imperfections in past practices and continued advances in scientific knowledge about the effects of chemical exposure on human health.

In light of the OMB's experience in reviewing agency rule-making, we read with considerable interest their critique of the federal government's risk assessment process, The HCRA has prepared a review because we have significant concerns about the balance and technical accuracy of the OMB report.

[6]

1991 Mar 15 W Gary Flamm of Flamm Associates (a long-term tobacco science-for-sale entrepreneur) has written an official report to Christopher J Proctor a lawyer at BAT (later at Covington & Burling)

Trip report to Harvard meeting on Peer Review of OMB/Risk Assessment report .

In January of this year I received the attached letter. As indicated in the letter, Harvard felt a closed, invitational workshop (which was held on March 6 & 7) was needed to peer review both the OMB report and Harvard's critique.

After some initial inquiries I was invited to participate in the meeting itself. After introductory remarks by John Graham about the purpose of the workshop and a very excellent presentation by Richard Belzner, we plunged into a peer review of the OMB report.

Flamm's comments about participants and the process:

  • Dr Ellen Silbergeld of the Environmental Defense Fund failed to attend. (Anti-smoker)
  • Franklin Mirer (clearly a 'liberal') who is Director of the UAW Health and Safety Department was openly hostile to the OMB report and recited a litany of alleged misstatements and distortions.
  • Dr Barbara D Beck who is a principal and head of Health Sciences at Gradient Corporation. and by Dr Colin Park from the Dow Chemical Company [both] expressed the view that OMB's criticisms were worth noting and had potential to improve the risk assessment process at federal regulatory agencies. They concluded that there was some justification to OMB's statement that risk assessments were "too conservative." [Beck was also a Toxicology lecturer at the HSPH and a close associate of Joe Brain [HSPH] and Peter A Valberg.
  • Loren Zeise was, as expected, rather critical of the OMB report, whereas my remarks were generally supportive.
  • W Gary Flamm was generally supportive.
  • Robert Silken [was] very supportive of OMB's criticisms of how risk assessment is currently done.
  • Mel Andersen basically threw in with Silken and reinforced the notion that it was good that OMB had criticized EPA and the other agencies for how they conduct risk assessments.
  • Dr Andersen, appeared quite disturbed over EPA's facility to twist and distort science to fit its own preconceived notions.
  • Dr Dale Hattes opened by talking about uncertainties, [and] left everyone confused.
  • Hopkins and Walten spoke [the next morning]. Both are economists and both were pleased with the substance of the OMB report and tried to say so without appearing overly enthusiastic. [T]hey managed to get across their point that risk assessments are often overly conservative and that some compliance/enforcement programs spend more than $100 million per life saved.
As it was apparent the review of the Harvard document would not go well, this discussion was cut short by John Graham. I think John realized that the more we talked about the Harvard report the worse the report was going to appear.

My own assessment of the meeting was that it was basically supportive of the OMB report, perhaps, to the surprise of its participants given the Harvard document was very negative.

Dr Gio B Gori and myself are planning through the International Society of Regulatory Toxicology and Pharmacology to undertake [another more controlled] workshop. At present we are planning to hold the workshop the first week of June. [7]
[Notes: Gio Gori was a notorious science-for-sale entrepreneur. This document was widely distribute among the disinformation staff and outside lawyers of the Tobacco Instititute, Philip Morris, and RJ Reynolds.
Also in this package is the participants list and the Harvard Center for Risk Analysis OMB document]



1991 June 26 A major two-day conference "Regulating Risk: The Science and Politics of Risk" was covered for the Tobacco Institute by Julia Sutherland from the PR company Fleishman Hillard (Not by the industry itself)

Speakers and others involved were

  • Peter Sandman, Dir. Environmental Communications Research Program, Rutgers University. [He spoke on the Importance of 'outrage' not just of 'hazard' [voluntary vs coerced/ natural vs industrial/ familiar vs exotic/ memorable vs forgettable, etc.]
  • Thomas A Burke, Johns Hopkins Uni, School of Hygiene and Public Health.
  • Richard B Blezer of OMB said that he had twelve staffers to review regulations for the five major health agencies: EPA, FDA, FAA, NHTSA and OSHA. Among other things that they review, they look at the regulations to ensure that risk reduction benefits are in line with the cost.
  • Carol J Henry, executive director, ILSI Risk Science Institute (Normally their rep would be Alex Malaspina)
  • Bernard D Goldstein, MD Dir Environmental and Occupational Health Sciences Institutes, Robert Wood Johnson Medical School
  • Roger O McClellan, DVM, President Chemical Industry Institute of Toxicology (CIIT)
  • Joseph V Rodricks, senior VP Environ Corp, {Note: ex-FDA; science-for-sale operator; also with AIHC]
  • Fred D Hoerger, Health and Enviornmental Services, Dow Chemical Co.
  • Vincent T Covello, Center for Risk Communication, Columbia School of Public Health [ex Nat. Science Found. White House Council on Environmental Quality]
  • John D Graham, Center for Risk Analysis, Harvard University School of Public Health.
  • Paul Slovic, president of Decision Research Co [Uni of Oregon/AAAS]
  • Lester B Lave, Graduate Schoolof Industrial Administration, Carnegie Mellon University
  • James L Emerson, DVM, director External Technical Affairs, Coca-Cola Company
  • Paul R Portney, VP Resources for the Future
  • Michael R Taylor, King and Spalding (lawyers) [8]

1991 Oct 21 John Graham at the Harvard Center for Risk Analysis has written to David Greenberg at Philip Morris promoting his organisation and seeking a donation.

He wants a face-to-face meeting "to learn more about the risk-related challenges that you face" and he also specifies an amount of $25,000 for each of the following two years to "help the Center expand its public policy activities." To stress its corporate inclinations, he also boasts that:

The Center has been launched primarily with gifts from the following corporations:

  • the Amoco Company,
  • Bethlehem Steel Corporation,
  • British Petroleum,
  • Chevron Corporation,
  • The Coca Cola Company,
  • Dow Chemical Company,
  • Eastman Kodak Company,
  • Exxon Corporation,
  • General Electric Corporation,
  • General Motors,
  • lnland Steel Industries,
  • Merck & Company;
  • Mobil Oil Corporation,
  • the Monsanto Company;
  • Pepsico Incorporated,
  • Rohm and Haas Company,
  • Texaco,
  • Union Carbide Corporation,
  • Westinghouse Corporation.
Government support has also been provided by the Centers for Disease Control, the US Department of Transportation, and the National Science Foundation. The Center is now looking to a broader base of industrial sources to supply critical funding for the years ahead.

He also has support from other right-wing and corporate organisation and from "leaders of other risk-related organisations:"

  • Paul R Portney of Resources for the Future,
  • llRoger O McClellan]] of CIIT [Chemical Industry Institute of Toxicology];
  • Thomas Grumbly of Clean Sites provided helpful advice. [Later the Health Effects Institute (HEI)]
    We owe a special debt to Vincent Gregory, retired chairman of Rohn and Haas Company, who helped us create a vision for the Center while persuading skepics at Harvard of the merit of our mission. [9]



1991 Jun 11 The International Society for Regulatory Toxicology (ISRTP) is holding a workshop in Crystal City, Virginia: Review of Risk Assessment and Office of Management and Budget (OMB)'s Report on its Application in Regulatory Agencies.

This one day workshop is a follow-up of the Harvard Workshop, which also reviewed the OMB Report. The participants include: Belzner, Scheuplein, Flamm, Gori and Wynder. (Three of the five are tobacco industry helpers)

The keynote speeches were:

[Note: W Gary Flamm was once president of the ISRTP, and Gio Gori was editor of its journal Regulatory Toxicology and Pharmacology. It numbers John D Graham and Dennis Paustenback among the illustrious group of corporate-friendly scientific hacks that make up its membership list.

Richard B Belzer, who stands out as an exception in all of these lists was an economist with Office of Information and Regulatory Affairs (OIRA) which is part of the OMB. He came to Washington 1988 after having studied at Harvard "under two prominent critics of risk analysis".]


1991 Jun 26 A major two-day conference "Regulating Risk: The Science and Politics of Risk" was covered for the Tobacco Institute by Julia Sutherland from Fleishman Hillard (Not by the industry itself) This was only a little over a week since the Virginia workshop. Speakers and others involved were

  • 'Peter Sandman', Dir. Environmental Communications Research Program, Rutgers University. Importance of 'outrage' not just of 'hazard' [voluntary vs coerced: natural vs industrial; familiar vs exotic: memoarable vs forgettable, etc.]
  • Thomas A Burke, Johns Hopkisn Uni, School of Hygiene and Public Health.
  • 'Richard B Blezer' of OMB said that twelve staffers review regulations for the five major health agencies: EPA, FDA, FAA, NHTSA and OSHA. Among other things that they review, they look at the regulations to ensure that risk reduction benefits are in line with the cost.
  • Carol J Henry, exe dir, ILSI Risk Science Institute
  • Bernard D Goldstein, MD Dir Environmental and Occupational Health Sciences Institutes, Robert Wood Johnson Medical School
  • Roger O McClellan, DVM, President Chemical Industry Institute of Toxicology
  • Joseph V Rodricks, senior VP Environ
  • Fred D Hoerger, Health and Enviornmental Services, Dow Chemical Co.
  • Vincent T Covello, Center for Risk Communication, Columbia School of Public Health
  • John D Graham, Center for Risk Analysis, Harvard University School of Public Health.
  • Paul Slovic, president of Decision Research
  • Lester B Lave, Graduate School of Industrial Administration, Carnegie Mellon University
  • James L Emerson, DVM, director External Technical Affairs, Coca-Cola Company
  • Paul R Portney, VP Resources for the Future
  • Michael R Taylor, King and Spalding [11]
[Note how often the same names turn up, often with conferences and workshops only days and weeks apart. This cabal of academics with libertarian political leanings were creating a new university discipline which came to be called Risk Assessment and Management -- with claims to superior insights -- out of what had once been simply known as cost-benefit analysis. Cost-benefit analysis had been inherent in all forms of regulation and legislation. They were being well funded in this endeavour by many large chemical/energy corporations.]

1991 Aug 20 Gio B Gori of the Health Policy Center, Bethesda, Maryland and W Gary Flamm of Flamm Associates are rapporteurs for a workshop on 'Cancer Risk Assessment. Flamm and Gori are both well-known tobacco scientific operatorst. The participanst include


1991 Sep 4 - 6 Workshop/Course in Risk Analysis in Occupational & Environmental Health held at the Harvard School of Public Health (HSPH), Boston.

  • Discussion Session 1 lists "Alar, Dioxin and Lead." The course leaders are almost all from Harvard University/School of Public Health. Graham is described as:

John D. Graham, Professor of Policy and Decision Sciences, and Director of the Harvard Center for Risk Analysis, Harvard School of Public Health, Boston MA [13]

[Note: There was no formal recognition of the name, Harvard Center for Risk Analysis (HCRA) before this date]

Others involved were:

  • Richard Wilson, Professor of Physics, Harvard Uni [Note: also a witness for the American Industrial Health Council (AIHC) (a front for the CMA)
  • Dale W Moeller, Professor of Engineering, HSPH [Note: Listed on 1994 advisory committee of ACSH with Frederick Stare and Elizabeth Whelan]
  • Howard Hu, Assist Prof of Occupational Medicine HSPH [No other references to him]
  • P Barry Ryan, Assoc Prof Environmental Health HSPH [He sent his C/V to Lorillard, and did airline cabin IAQ monitoring work. 336 documents in tobacco archives] [14]
  • Joseph D Brain, Prof of Environmental Health, HSPH Also Director of Respiratory Biology Program. [On list of scientists enlisted to peer-review the science behind the Premier cigarette for RJ Reynolds - 279 documents in archives.]
  • Philip Cole, Epidemiology, University of Alabama Medical School {Beware: 3 Philip Coles} [PH Cole was at HSPH in 1977 - tobacco witness] [15]
  • Edmund Crouch, Senior Scientist, Cambridge Environmental Inc [He was a Physicist]
  • Arthur C Upton, Institute of Environmental Medicine, NY University Med School [ex Dir. National Cancer Institute, but also a friend and supporter of Gio Gori
  • Peter A Valberg, Adjunct Associate Professor of Physiology, HSPH and Gradient Corporation [$330 per hr witness for Philip Morris on inhalation toxicology; involved in organising scientists peer group on RJR Premier cigarette - 79 documents in archives under his name, more under Gradient.]
  • Arthur Langer, Environmental Sciences Laboratory, Brooklyn Colleges
[Note: This is a 709 page document] [16]

1991 Oct Ralph Nader's Public Citizen report on Graham says:

It appears that Graham first became involved with Philip Morris in October 1991. On October 18 of that year, he called [Mayada] Logue to set up a meeting in Washington, and the meeting was duly scheduled. On October 21, Graham solicited donations from Philip Morris to HCRA.

Graham's letter noted that the Center had "major projects underway in carcinogen classification, risk assessment, public health priorities, and the use (and misuse) of risk numbers in environmental legislation." He wrote:

The Center has been launched primarily with gifts from the following corporations: the Amoco Company, Bethlehem Steel Corporation, British Petroleum, Chevron Corporation, The Coca Cola Company, Dow Chemical Company, Eastman Kodak Company, Exxon Corporation, General Electric Corporation, General Motors, Inland Steel Industries, Merck and Company, Mobil Oil Corporation, the Monsanto Company, Pepsico Incorporated, Rohm and Haas Company, Texaco, Union Carbide Corporation, and Westinghouse Corporation.
[17]

[1]


1991 Oct 29 At Philip Morris, Robert A Pages was commenting to Steve Parrish on a letter from John Graham (Oct 21)

My reaction: I think that a meeting should be arranged with Graham when he calls Greenberg and that you should try to attend. It doesn't hurt to talk to the guy - he says: "It is important for me to learn more about the risk-re1ated challenges that you (PM) face."

Why not take him up on the offer? Sure, he's after money to help support his Center, but whether or not PM decides to contribute it's more important to meet him and perhaps get 'looped in' better with his activities. From all that Mayada (Logue) has learned, he is a key player in all this risk analysis stuff that's currently going on in the government.

Depending on the 'vibes' you guys get when you meet Graham, I would also be in favor of PM becoming a contributor to the Center. [18]
[Philip Morris was as cynical as you'd expect about Graham's self-promotional attempts. Everyone was trying to jump on the 'Risk Asessment" bandwagon when it became apparent how useful it was to corporation following ILSI's success. Later Philip Morris became a key supporter of Graham's operations. In 1991 they drafted a $25,000 check to HCRA, but Harvard University wouldn't accept tobacco funding so the check needed to be redrafted in August 1992 as a $20,000 check from Kraft General Foods to hide its origins.] [19]

1992 Mar Graham says that in the spring of 1992 he was asked by C Boyden Gray to provide advice on a risk executive order. He says that he then established the Risk Management Reform group in 1994

In the spring of 1992, the Bush Administration began development of a new presidential executive order aimed at bringing more scientific rigor and political accountability to the process of health, safety, and environmental regulation. At the time, I was asked by the Counsel to President Bush, C . Boyden Gray, to provide advice on the development of the executive order. My basic concern, shared by Mr. Gray, was that the regulatory process seemed to be overreacting to small and speculative risks while leaving larger and more certain risks unattended. The insights that could have been provided by the emerging science of risk analysis seemed to be poorly used by federal regulatory agencies. The stakes were large: unnecessary death and illness, preventable harm to the natural environment, and wasted economic resources .

A political judgment was made in the summer of 1992 that such a far-reaching reform should not be launched in the middle of a Presidential election campaign . After the election, the momentum for reform of risk regulation was not lost. In 1993 President Clinton issued an executive order on regulatory planning and review that gave some attention to the need for sound risk assessment and cost-benefit analysis . Congress also began to expYess serious interest in the issue . In particular, Senators Bennett Johnston and Daniel Patrick Moynihan, as well as several members of the House, began introducing bills on this issue .

In 1993 I approached Mr. Gray, who had returned to the practice of law at Wilmer, Cutler and Pickering, about the need for systematic thinking about how the process of risk regulation should be reformed . Mr. Gray agreed to work with me in an effort to identify a distinguished group of scholars and practitioners who might collaborate with us in the design of a solution. The Harvard Center for Risk Analysis (HCRA), whose mission is to promote reasoned public responses to health, safety, and environmental hazards, served as sponsor of the Group and a technical resource on the scientific aspects of risk analysis .

With the assistance of Mr Gray, HCRA received a grant from the Lynde and Harry Bradley Foundation to convene the Group . Our goal was to devise a concrete set of recommendations that Congress and the President might consider in their deliberations about regulatory reform .

See page 5 [20]


1992 Mar 2 Mayada Logue of Philip Morris reports to her boss Steve Parrish that she'd had discussions with Graham about his meetings with tobacco lobbyist Thorne Auchter [ex OSHA] and (RJ Reynolds/think-tank operator) C Boyden Gray who had been counsel to President George HW Bush (and later to GW Bush)

During this period under President HW Bush, Thorne Auchter had been paid by Philip Morris to lobby for an Executive Order making Risk Assessment mandatory for all of the health and environmental regulatory agencies. Boyden Gray was an ex tobacco lobbyist (and heir to the RJ Reynolds Tobacco fortune) who worked through the Republican think-tanks Citizens for a Sound Economy and Citizens for a Sound Environment as well as providing legal counsel services to both President Bushs.

Lunch meeting with John Graham who gave me specifics on two meetings he had. One with Thorne Auchter concerning the Executive Order and the other with Boyden Gray, President Bush's General Council.
John Graham is writing a book about the unintended risks we take when attempting to avoid other risks. There will be a chapter on smoking in the book. He said that most of the information in that chapter is from the Surgeon General's Report and asked if we would review it for accuracy. Bob Pages has agreed to review it.

[Note: 1. Bob Pages was an in-house scientific lobbyist at Philip Morris with the title Senior Scientist and, at that time' the director of the PR division known as "Science & Technology". Graham seems to have thought that he would be the obvious person to 'review' a piece on smoking risk "for accuracy".
2. Thorne Auchter was paid by Philip Morris to lobby for an Executive Order making Risk Assessment mandatory for all of the health and environmental regulatory agencies.
C Boyden Gray was an ex tobacco lobbyist (and heir to the RJ Reynolds Tobacco fortune) who worked through the Republican think-tanks Citizens for a Sound Economy and Citizens for a Sound Environment.] [21]

1992 May 2 New Scientist article. Graham was interviewed for an article "Time To Reform Toxic Tests", where expressed the opinion that the costs of regulation may actually be killing more people than the chemicals which the regulations were being enforced to control. He argued that regulatory costs of $175 billion each year in the USA was impoverishing the whole society, forcing some people down to a standard of living so low that it resulted in illness or premature death.

The article was written to promote the idea that scientists were overusing animal tests for chemical toxicity. It also quoted Francis JC Roe (a well established English tobacco/science lobbyist) who was promoting the idea that there are threshold levels, below which toxic substances have no adverse reaction. This was a popular idea with the tobacco industry fighting the battle of passive smoking. With some exaggeration, Roe attacked ...

... the flawed belief that weak toxic effects are most likely to be discovered by determining the effects of very high doses of test chemicals (which leads to) the requirement to test chemicals for carcinogenicity at the maximum tolerated dose level, even when this level is 100, 1000, or more than 10,000 times the human exposure dose."[22]



1992 May 4 Mayada Logue at Philip Morris reports:

8. Had discussions with Dr Vince Covello concerning a presentation by him on Risk Communications and Science to PM personnel. That seminar will be presented by Dr Covello at the NY Office June 22 from 1:00 to 4:00 p.m.

9. Meeting with Dr Rick Guardia concerning John Graham and the Harvard School of Public Health which resulted in my setting up a meeting with Dr Guardia, Dr Graham and myself in May in Tarrytown.

10. Arranged a meeting between J Graham , myself, D Keane and L Dreyer in Washington D.C. This will take place in June.

The activities she had planned for later in May 1992 included:

2. Meeting with Dr Graham and Dr Guardia in Tarrytown, NY 4. Attend CRAM (Committee on Risk Assessment Methodology) workshop on Quantitative Methods in Developmental Toxicology. 5. Attend Harvard School of Public Health's "Symposium on Occupational Health Risk Assessment : Directions for the 90's." [23]


1992 Jun 26 John D Graham writes to Jonathan Baert Wiener at the Bush White House's Office of Science and Technology Policy. Wiener was working on the draft Executive Order on Regulatory Review (not signed by Bush, and modified before being signed by Clinton. This letter was sent by Graham to Philip Morris (probably as proof of providing a contracted service).

"The Release of Risk Assessment as a Regulatory or Policy Action: The Case of ETS." In this, he complains that the EPA's risk assessment of secondhand smoke was exaggerated, and would overload state and federal agencies, including the Occupational Safety and Health Administration (OSHA), and

in the longer term, the report may help stimulate a whole new wave of tort liability litigation by nonsmokers who work and/or live with smokers.

He then raises tobacco's favourite 'Slippery Slope' argument -- the idea that when you regulate one industry, all other industries are similarly threatened with interference:

In light of this example, think more hroadly about future. A risk assessments of electromagnetic fields, video display terminals, styrene, formaldehyde, carbon dioxide emissions, and so forth.
As matters stand now, the White House and the nation are very vulnernable to EPA (or other agency) risk assessments that are not based on sound science or do not adequately convey the degree of uncertainty in the science. [S]ince I am not an expert on ETS, I don't know whether EPA's report is based on good science [but] if one is trying to make a case against smoking, the EPA risk assessment is certainly good ammunition.

Graham suggested that the risk assessment process on ETS and other substances should be part of a formal rulemaking process with a small team of specialists [like himself] in the White House. [24]

Graham then sent a copy of this letter to Mayada Logue, who has distributed it around Philip Morris USA corporate office. [25]

He ends by saying

"I hope this memorandum has provided you a concrete example of the need for strong White House authority and expertise in the field of risk analysis. Good luck in your work!"

[He is trying to gain more 'brownie points' with PM by enlisting Wiener into the HRCA (he succeeds)] [26]

[Note: There is no mention of him having recently solicited money from Philip Morris. Graham and Wiener later wrote a book together on comparative risk assessment, Risk v. Risk: Tradeoffs in Protecting Health and the Environment, and both of them testified in 1995 on the need for regulatory reform before the Senate Committee on Governmental Affairs.]
Risk-vs-Risk : Tradeoffs in Protecting Health and the Environemtent
“John Graham and Jonathan Wiener develop their thesis that unless risk tradeoffs are considered in reducing risks, well intentioned, costly measures may fail to deliver the expected protection of the environment, safety or health. In brief, Graham and Wiener begin by describing a framework for ‘risk tradeoff analysis,’ then document the significance and complexity of risk tradeoffs in a range of real-world issues, and conclude by proposing a holistic approach to reducing risk. Professionals and policymakers engaged in risk management and risk communication will find this book illuminating and immensely useful.”—Mona S Rowe


1992 Aug 12 Dr Enrique J Guardia ('Rick'), the VP of Scientific Relations at Kraft General Food (a Philip Morris subsidiary) writes to John Graham. [ccd also to Tom Borelli, Mayada Logue (both with PM tobacco), Robert McVickar (KGF Foundation, which acted as a front group for tobacco), James Serafino (KGF's "Scientific/Issues Manager"). Graham has asked Philip Morris and Kraft General Foods to help him raise $25 million for his Harvard Center of Risk Analysis. Rick Guaria replies:

I am delighted that HCRA is launching an effort to increase food industry support for work on food safety legislation. This, as we discussed, is a very important issue that would profit from rigorous risk analysis discipline.

I think your letter tells the story well, so I would not change it. You know more about fund raising than I, but your request of $25 million strikes me as excessive in a year like 1992. Ask yourself whether you would not be better off asking for $10 million.

Enclosed is a list of participants from the Industry to the Keystone dialogue on Food Safety. This may provide you with specific names and companies to consider, however, your list looks very complete. Lastly, I am in the process of processing Kraft General Foods contribution to HCRA. As soon as it clears our internal bureaucracy I'll be in touch. [27]

[Note: this was also obviously a tobacco deal, with the funds being 'laundered' through the food company.]



1992 Aug 30 The Worldwide Regulatory Affairs division of Philip Morris is setting up a brainstorming session with the company's Richmond scientists together two who had flown in from Europe (Neuchatel). Scrawled writing indicates that those at the meeting had plans for Graham's participation: "Need a war of words European v. USA Studies, etc. — J. Graham Ast. Symposium. [28]


1992 Aug 31 Mayada Logue memo to Steve Parrish at Philip Morris Management Corp (also ccd to Borelli, Keane, Pages, Pottorff and Purcel -- all tobacco disinformation experts.) [These copies are clearly meant for the files. They are worded to pretend that the food company was the key client, and not tobacco.]

John Graham/Harvard Center for Risk Analysis
The attached documents attest to the fact that the meeting between myself, Dr Guardia and Graham was beneficial in that The Harvard Center for Risk Analysis (HCRA) has launched an effort to address issues in food safety legislation.
I am pleased with this development and hope that we can continue to work with and support Dr Graham's work on issues that involve Risk Analysis. [29]


1992 Aug 31 Mayada Logue's notes (p 47 " - John Graham -- Kay Packett lunch) -- discussed with D Keane. Need to schedule meeting with J.Graham & Pages. [30]

1992 Oct 5 Mayada Logue of Philip Morris records a Washington meeting between Graham in Washington and Robert A Pages (head of PM Science & Technology) [31]


1992 Dec 1 American Industrial Health Council, (AIHC) Annual meeting. Graham is listed as the Moderator on the Risk Assessment panel

John D. Graham, Ph.D. Director, Center for Risk Analysis , Harvard School of Public Health [32]
[Note that CRA hadn't split away from the HSPH at that time. It was still attached to Harvard University]

1993 May 24-25The International Institute at George Mason University (GMU) and Fred Singer's Science and Environmental Policy Project (SEPP) were jointly running a climate-denial conference Scientific Integrity in the Public Policy Process. SEPP had been set up as a tobacco front by APCO, the semi-private public-relations firm controlled by Philip Morris via Arnold & Porters (their Board-level lawyers). Graham spoke at this conference along with about 20 well-known tobacco 'scientist-friends'. On the list of speakers, the most obvious were: Robert Tollison (who ran the Cash-for-Comments Economists Network); John H Moore who worked for the American Chemical Society and was Chairman of the Board of ACSH and with the Hoover Institute (both at GMU); Michael A Fumento syndicated journalist with the Hudson Institute; Michael Gough (ex OTA and associate of Steve Milloy); S Fred Singer of SEPP; Michel Salomon ICSE and Heidelberg Appeal; Fred L Smith of the CEI; Kip Vicusi, of Duke Uni; Peter Huber of the Manhattan Institute; Richard Linzen of MIT (consultant to fossil fuel industry). [33]

A Philip Morris record which circulated quotes of the potential speakers -- those attacking the EPA's risk assessment of passive smoking -- was compiled for general use in the tobacco industry. One section says:

SEPP is an independent, non-profit research group that relies on private funding. It will co-sponsor a conference with George Mason University in May on scientific integrity in the political process. Candace Crandall (Executive VP of SEPP) has published extensively on junk-science issues in the past. Crandall has arranged for a number of prominent scientists to be participants, including Dr Bernard Davis of Harvard University and Sir William Mitchell of Oxford University. Crandall is Dr Fred Singer's wife. [Note: the document is misdated; must be early 1993] [34]



1993 May 31Michel Salomon is running a Heidelberg follow-up seminar at the ICSE in Paris. It is to be a restricted scientific seminar on "The Linear Relationship" (a theme which promotes the idea that there are no-effects thresholds for all toxic substances.} This is the first meeting of his "International Center for Scientific Ecology" (ICSE) His speakers include Graham, Singer, Ames, and a number of other tobacco lobbyists including Peter N Lee. The guests are to be "invited industrialists and government representatives".

It questions the use of animal studies in cancer research, and provides case studies in arsenic, asbestos, Vinyl/chloride-derivatives, EMF/nuclear radiation, DDT, Saccharine and passive smoking (by staff or lobbyists for the producers).

Questions arise when decision centres, trade unions, associations and "environmentalists" - in short, lobbies as a whole, seizing on the observations that a substance is "carcinogenic in high concentrations", put increasingly heavy pressure on the scientific community (and on epidemiologists in particular) to obtain data assessing the risk to populations, who, at work or in their everyday life, are subject to low -- even very low -- concentrations of substances proven carcinogenic in high doses.

They were fighting the Delaney amendment to the "Food Drug and Cosmetics Act" in the USA, and Irwin Selikoff (asbestos researcher and activist) who said "One fibre can kill".

The Board of the ICSE is Pierre Joly, the ex President of the International Federation of Pharmaceutical Manufacturers Associations; S. Fred Singer of SEPP; Constant Burg, MD of INSERM ( French National Institute of Health and Medical Research.); Gilbert Rutman, mining engineer and Chair of their association (CNISF); Gary Nash, Sec-Gen. of the International Council on Metals and the Environment (ICME); and Michel Salomon, the 'coordinator of the Heidelberg Appeal". SEPP is listed as a patron.

[35] [36]



1994 John D Graham has now created the Harvard Group on Risk Management Reform (as part of the Harvard School of Public Health) at the request of President Bush's key legal advisor, C Boyden Gray

[Note: Gray was an heir to part of the RJ Reynolds Tobacco fortune, and he later established the corporat[ think-tank, the Citizens for a Sound Economy.]


1994 Nader's Public Citizen reported

Graham was a member of the EPA Science Advisory Board (SAB) that reviewed the agency's risk assessment on dioxin, an industrial contaminant, in 1994 and 2000.

In June 2000, the EPA announced a draft of its study, which showed that exposure to the level of dioxin currently in our environment causes an increase in the average American's lifetime cancer risk to as high as 1 in 100. The EPA's reassessment also found that dioxin, even at very low levels of exposure, is linked to infertility, immune system damage and learning disabilities.

But rather than acknowledging that dioxin poses an additional threat to human health, in his comments to the media Graham misleadingly downplayed the risk by comparing the EPA's findings to other types of risks, such as the risk of dying in a car crash. When compared with these risks, Graham suggested, the risk posed by dioxin appears "normal."

The National Public Radio report containing Graham's comments failed to mention his position on the Science Advisory Board and failed to disclose that his Center is supported by money from 48 different dioxin producers, including incinerator companies, pulp and paper companies, cement kilns, copper smelters, PVC manufacturers, PCB producers and the petroleum industry.

[37]

1994 Graham was a member of the EPA Science Advisory Board (SAB) that reviewed the agency’s risk assessment on dioxin, an industrial contaminant, in 1994 and 2000. [Public Citizen expose ]


1994 Graham’s tight connections to the chemical industry have also influenced his legislative work. Graham spoke at a panel discussion held around 1994 at the Chemical Industry Institute of Toxicology (CIIT) alongside executives from Eastman Kodak, the American Industrial Health Council, Air Products and Chemicals, E.I. DuPont de Nemours, and the Chemical Manufacturers Association (now called the American Chemistry Council). [38]

The topic was a Congressional bill that would have imposed rigid cost-benefit criteria on federal regulatory agencies in order to deter the development of new public health, safety and environmental protections.

Graham commented on the relationship between the rollback "reform" bill and the chlorine’s industry’s support for institutions such as CIIT:

"Those of us advocating reform could not be as effective as we have been in advocating the role of science in risk assessment if we did not have the underlying data and methodologies that were created here at CIIT,"

He said. All of the trade associations and companies listed are also funders of Graham’s Center. [Public Citizen expose.]


1994 Graham was commissioned by the conservative American Enterprise Institute to (according to his own later testimony before the Senate)

write a blueprint for regulatory reform legislation. This blueprint influenced the regulatory legislation that passed the House of Representatives in March of 1995.

(The bill failed to pass the Senate.) Graham's claim is probably an exaggeration, but it is true that he had a distinct media presence in the debate over regulatory rollback. Graham told an audience at the Heritage Foundation in 1996, "I don't think there's any more passionate advocate of regulatory reform than myself." [39]


1994 John D Graham of Harvard Center for Risk Assessment was enlisted as a member of the Environmental Protection Agency's first (1994) Science Advisory Board on the risk assessment on dioxin.


1994 promoting CEI claims about fuel efficiency in mid 1994 CAFE standard. 2046558291


1994 Feb Notes of meeting over tactics/strategies
" Epidemiology - J Graham - conference"[40]


1994 Aug 11 The Alexis de Tocqueville Institute has produced a report by S Fred Singer of SEPP via Philip Morris's own PR-firm APCO, for the tobacco industry and other industries in a small coalition. This was first sent to the Tobacco Institute for approval. The Institute then advised its Management Committee [41]

The report was a well-funded, well-camoflagued attack on the activist concerns about Environmental Tobacco Smoke (ETS), which hid behind the potential problems raised by the Environmental Protection Agency (EPA) over radon, pesticides and the SuperFund toxic chemicals in the environment. It says:

" Science, Economics, and Environmental Policy: A Critical Examination" is an evaluation of the data, statistical analyses, and underlying scientific theories that underlie the Envirorunental Protection Agency's (EPA) policy decisions on environmental tobacco smoke, radon, pesticides and hazardous clean-up under the Superfund law.

With the total costs of environmental regulations estimated to be $150 billion annually -- or $1,500 per U.S. household -- it is extremely important that environmental decisions be based on sound scientific analyses of potential risks to public health and the environment, and that the costs of environmental regulation be weighed against the benefits. [Note the lack of conculsions that it was even more important for American industry to clean up its act and stop polluting!]

But as Dr John Graham of the Harvard Center on Risk Analysis notes, "While it may seem obvious that EPA should use good science, students of the Agency have documented that the Agency's leadership, when preoccupied with public fears and legal pressures, has sometimes allowed good science to be neglected."
[Of course, no one mentioned that John Graham and his Harvard Center for Risk Analysis were also tobacco industry-funded lobbyists.]

The aim of this report was to group together a number of different environmental threats (which most Republicans had been convinced were fallacious), create a giant scarecrow, then classify them jointly as examples of the EPA's strawman threats to health. This, they held, was evidence of the radical agenda of the EPA and other anti-smoking, anti-polluting zealots.

The Advisory Panel for this operation comprised Robert Tollison, Richard Wagner, Dwight Lee, Gary Anderson, Mark Thornton, Robert Ekelund, Jeffrey Clark, and Richard Vedder -- all from the Cash-for-Comments Economists Network --as well as a few other tobacco industry consultants and well-known lobbyists. [42]


This report market a turning-point in the tobacco industry's fight-back operations. Philip Morris had just successfully established The Advancement of Sound Science Coalition (TASSC). Steve Milloy at TASSC had the job of labelling any anti-tobacco study results as 'junk-science' and APCO who secretly ran TASSC, had extended the reach of this new 'junk-science' operation to embrace mutual-help relationships with the major poisoning and polluting industries which were becoming embroiled in the problems of climate change. This was one of the tobacco industry's contributions to the 'anti-science' movement which was intended to counter both anti-smoking and climate change research.

1994 Sep Ralph Nader's Public Citizen report on John D Graham says:

In the fall of 1994, Graham was commissioned by the conservative American Enterprise Institute to (according to his own later testimony before the Senate) "write a blueprint for regulatory reform legislation. This blueprint influenced the regulatory legislation that passed the House of Representatives in March of 1995." (The bill actually failed to pass the Senate.) [43]

Graham’s claim is probably an exaggeration, but it is true that he had a distinct media presence in the debate over regulatory rollback. Graham told an audience at the Heritage Foundation in 1996, "I don’t think there’s any more passionate advocate of regulatory reform than myself." [44]

Then again in late 1994, Graham became a prominent figure in the Washington establishment debate over the merits of so-called regulatory "reform." Under the 'Contract With America, Republicans had pledged to subject most new regulation on the part of a dozen federal agencies — and especially the EPA — to an obstacle course of hurdles like risk-benefit analysis and cost-benefit analysis, along terms drafted by business interests.55 There were several bills floated on the topic, but only fragments of the rollback initiative were eventually signed into law.


{NEEDS CORRECTION} 1994 Oct finged on GEP with Federal Focus +++++++++++++++++ 2048781911

Filtrona Ltd, UK 26 Oct 1986 - 401157969


1994 Oct 13 - 14 Lansdown Panel, "The proper role of epidemiology in Risk Analysis. Boston,. Run by John D Graham (edited - published Elsevier) 2040401681????NOT ???>Graham is said to be at Lansdowne meeting preliminary to London Conference on GEP. [He is not on this agenda list] [45]


1994 Dec /E The Washington Post, Feb 8 1995 carried an article "Assessing the Risk In Contract's 'Cost-Benefit' Curb on Regulation. It said that ...

... then again in late 1994, Graham became a prominent figure in the Washington establishment debate over the merits of so-called regulatory "reform."

Under the Contract With America , Republicans had pledged to subject most new regulation on the part of a dozen federal agencies — and especially the EPA — to an obstacle course of hurdles like risk-benefit analysis and cost-benefit analysis, along terms drafted by business interests.

  • The House bill: '"Risk Assessment and Cost-Benefit Act of 1995," required a formal risk assessment for any proposed rule likely to result in annual increases in costs to government, industry and consumers, of more than $25 million annually, or "about 10 cents per American per year."

Based on the assessment, the agency could regulate only if:
1) the risk reduction or benefits are "likely to justify, and be reasonably related to, the incremental costs," and
2) all other alternatives are "less cost-effective," or provide "less flexibility" to those being regulated, such as businesses.

The bill also had a comparative risk component, requiring federal agencies to compare any risk they estimate with other risks in daily life, and to take account of "substitute risks" — which are hazards that happen because of efforts to eliminate risk. There were several bills floated on the topic, but only fragments of the rollback initiative were eventually signed into law. [46]

1994 Dec 1 2 073426570 (Members of Annapolis Center Board early


1995 The Human and Ecological Risk Assessment journal has a report on the Harvard Group on Risk Management Reform. at the Harvard School of Public Health. It says that the Group had been founded by JD Graham in 1994 at request of C Boyden Gray while Counsel to President Nixon, to help developent of a new presidential order which "aimed at bringing more scientific rigor and political accountability to the process of health, safety and environmental regulation" This process continued after Clinton win in 1993. Gray obtained a grant for the HCRA [Note: the Center, not the Group] from the Lynde and Harry Bradley Foundation. It listed ...

Members of the Harvard Group on Risk Management Reform (HGRMR)

  • C Boyden Gray (Group Chair) former counsel to the president.
  • Frederick R Anderson, former president Environmental Law Institute [partner in Cadwalader Wichersham and Taft]
  • Baruch Fischhoff, Prof of Social and Decision Sciences, Carnegie-Mellon Uni [One of the pioneers of legitimate risk assesssment studies.]
  • Lois Swirsky Gold, Lawrence Berkeley Lab, & Uni of California Berkely (Partner of Bruce Ames) She is linked to TASSC, and later to the Annapolis Center (NAM)
  • Donald Hornig, Harvard School of Public Health, ex Science Advisor to President Bush; member of AIHC and HSPH with Graham. Science adviser to Pres. Lyndon Johnson.
  • Sheila Jasanoff, Prof of Science Policy & Law, Cornell Uni
  • Mart Landy, Prof of Political Science, Boston College
  • R Shep Melnick, Prof of Politics, Brandeis Uni
  • Richard A Merrill, Prof of Law, Uni of Virginia; ex chief counsel FDA (DHHS); ex tobacco lawyer with Covington & Burling in 1970s and mid 1990s, worked with Myron Weinberg's WashTech science recruiters.
  • Paul R Portney, CP, Resources for the Future, ex Senior Economist, Council on Environmental Quality
  • Charles Powers, Resources for Responsible Management. [co-consultant/co-author/husband of Barbara Ley Toffler at Harvard). At various times he ran Health and Environment Institute (HEI, Clean Sites (CS), and Clean Sites Environmental Services (CSES - for profit), Partner in Resources for Responsible Management (RRM for profit); President of Institute for Responsible Management (IRM non-profit); President for Resources for Responsible Site Management (RRSM for-profit) and Institute for Evaluating Health Risk (IEH)

Also (executives who were not risk-managers)</u<

  • William D Ruckelshaus, CEO of Browning Ferris and the ex-Administrator of the EPA [Also the founder/CEO of Health Effects Institute and Clean Sites'.]
  • Richard Stewart, Prof of law New York Uni, and Assistant Attorney-General for Environment and Natural Resources, US Dept of Justice
  • Cass R Sunstein, Prof of Jurisprudence, Uni of Chicago [male - 'free-market fundamentalist" - with Obama admin]
  • Rae Zemmerman, Prof of Planning and Public Admin, New York Uni

Project Staff

Nancy Beaulieu, Harvard Uni
John D Graham, HSPH and HCRA
Marc J Roberts, Prof of Political Economy, HSPH [Enlisted by Myron Weinberg's WashTech group as witness]
Ms March Sadowitz, Researcher HCRA, and JD student, Boston Uni School of Law
Jonathan B Wiener, Prof of Law, Duke Uni (also a HCRA advisor)

Their report recommended

  1. Moving the control of regulatory risk assessment over from the statutory authorities to the Office of Science & Technology Policy (OSTP) and Office of Management and Budget's Office of Information and Regulatory Affairs OMB-OIRA.
    : [Note: This was later controlled by Graham at the White House level, and therefore directly under political control.
  2. Congressional legislation requiring all federal agencies to perform cost-benefit analysis and to hold public hearings, citizens panels, and conduct social science research. [Which would immeasurably slow down the process of regulation]
  3. Congressional regulation should have flexibility -- allowing for the substitution of alternative plans or 'deals' (for say a toxic cleanup)
  4. Congress should transfer selected risk-management powers to the state and local authorities (Safe Drinking Water Act and Superfund program) [47]

1995 March '"Reform of Risk Regulation: Achieving more protection at Less cost" (Harvard Uni, JD Graham)
Paul R Portney, VP 'Resources for the Future in DC, and a former Senior Economist with the Council on Environmental Quality is now closely associated with John D Graham's Harvard Center for Risk Analysis, and a member of the Harvard Group on Risk Management Reform ( which is now chaired by C Boyden Gray) [48]

Ralph Nader's Public Citizen report on John D Graham, says about C Boyden Gray:

Gray also served as "Group Chair" of the "Harvard Group on Risk Management Reform," a 15-member group which headed a 1995 effort for regulatory rollback. Gray is a prominent lobbyist for chemical, steel and energy interests. [49]




1995 An article in the National Journal in 1995 described Graham's promotion to a top position within the Chamber of Commerce as a sweeping, inter-agency requirement:

John D. Graham... predicted that the risk assessment legislation will be the first installment in a 10-year overhaul of federal health, safety and environmental policies. During that time, he said, Congress should rank all the risks with which the federal departments and agencies must deal and shift resources to focus on the most dangerous ones.

1995 Another article in The Boston Globe described the Superfund cleanup of chemical contamination of Love Canal, New York. After the EPA filed a lawsuit over the cleanup, Occidental Chemical Corporation and the government reached an agreement that Occidental would reimburse taxpayers for $129 million of the costs. Thanks to EPA's efforts, Occidental — which inherited the legal liability for 20,000 tons of chemicals that were dumped in Niagara Falls, NY, over the course of nine years — and not taxpayers, were footing the bill. Yet Graham was quoted in the article as saying, "Does it really make sense to spend, say, $50 million on speculative risks when you don't have the resources to provide violence-prevention or pregnancy-prevention in the schools?" Graham failed to mention — or the reporter failed to report — that two of his Center's funders, Millenium Chemical and Lyondell Chemical, are Occidental's petrochemical business partners. Graham's comments are also misleading because reducing costs to industry does not free up money for government programs that address other risks as Graham implies. Instead, the money goes back into shareholders' pockets. [50]


1995 March The Center for Risk Analysis at the Harvard School of Public Health has published "Reform of Risk Regulation: Achieving More Protection at Less Cost" The Chair of this group is C Boyden Gray who, in the Clinton era, had moved into the think-tank world with his Citizens for a Sound Economy (CSE) scam. The members are the same old group listed above in various combinations. [51]


1995 May 15-16 Morton Lippmann is now Chair of the Health Panel for the Dioxin Reassessment Review being done by the EPA: Jan Daisey is from the Lawrence Berkeley Laboratory, and the Chair of the Exposure Panel Consultants include: [52]



1995 Jul 12 CNN Moneyline, "GOP Bill Would Repeal Ban on Some Pesticides," by Irv Chapman, quoted Graham as a "scientist" who supported Sen Dole's reform bill as "based upon sound scientific principles".


1995 Sep 8 on SAB of EPA as consultant 89232947



1995 Oct The London Principles Principles for Evaluating Epidemiologic Data in Regulatory Risk Assessment. This was part of the move by Philip Morris to create Good Epidemiological Practice (GEP) standards which would hamper the regulatory agencies in their labelling of harmful substances. They built their GEP on an earlier version developed by the Chemical Manufacturer's Association (CMA) and following a preliminary Landsown Conference run in the USA by Philip Morris in 1994.

The London 'Expert Panel Members:

  • John Ashby, Ph.D.
    Honorary Professor, Department of Biological Sciences University of Wales, Swansea, and Research Associate, Zeneca Central Toxicology Laboratory Macclesfield, Cheshire, UK
  • Dr George Carlo, Ph.D., J.D. Chairman, The Carlo Institute and Health and Environmental Science Group, Ltd., and Professor, The George Washington University Washington, DC, USA
  • Dr Samuel M Cohen, M.D., Ph.D. Professor and Chairman, Department of Pathology and Microbiology University of Nebraska Medical Center, and Professor, Eppley Institute for Cancer Research Omaha, Nebraska, USA
  • John S Evans, Sc.D. Senior Lecturer on Environmental Science, and Director, Program in Environmental Health and Public Policy, Harvard School of Public Health Boston, Massachusetts, USA
  • John D Graham, Ph.D.** Professor, Policy and Decision Sciences, and Director, Center for Risk Analysis Harvard School of Public Health Boston, Massachusetts, USA
[** Graham was now Co-Chair of Workgroup on Dose-Response and Member of Organizing Committee
  • Walter Holland, M.D., FFPHM. Emeritus Professor of Public Health Medicine University of London, and Honorary Senior Research Fellow Royal College of Physicians London, England, UK
  • Linda C Koo, Ph.D.* Honorary Head, Cancer Research Laboratory Hong Kong, Anti-Cancer Society Nam Long Hospital, and Department of Community Medicine University of Hong Kong
[* Co-Chair of Workgroup on Hazard Identification and Member of Organizing Committee. Linda Koo was actually a notorious Asian WhiteCoat working for Philip Morris, and the girlfriend of the Swedish Karolinska Institute corrupt scientist Ragnar Rylander who was even more notorious.
  • Genevieve M Matanoski, M.D., Dr.P.H. Professor of Epidemiology School of Hygiene and Public Health, The Johns Hopkins University, and Faculty of Preventive Medicine University of Maryland Baltimore, Maryland, USA
  • D. Warner North, Ph.D. Senior Vice President Decision Focus, Inc. Mountain View, California, USA
  • Dennis J Paustenbach, Ph.D.** Vice President and Chief Technical Officer Chemical Risk Division McLaren/Hart Environmental Engineering Corp. Alameda, California, USA
** Co-Chair of Workgroup on Dose-Response and Member of Organizing Committee. Paustenbach is another well-known general industry scientific lobbyist.
  • Goran Pershagen, M.D., Ph.D. Professor, Department of Epidemiology Institute of Environmental Medicine Karolinska Institute, and Chief Physician, Department of Environmental Health Karolinska Hospital Stockholm, Sweden
  • James J. Schlesselman, Ph.D. Professor, Department of Family Medicine and Clinical Epidemiology, and Chief, Division of Biostatistics School of Medicine University of Pittsburgh Pittsburgh, Pennsylvania, USA
  • Thomas B. Starr, Ph.D. Health Sciences Division, ENVIRON International Corp. Raleigh, North Carolina, USA
ENVIRON had a division that did fake IAQ testing for the tobacco industry.
  • James A Swenberg, D.V.M., Ph.D. Director, Curriculum in Toxicology, and Professor of Environmental Science, Engineering, and Pathology University of North Carolina Chapel Hill, North Carolina, USA
  • Mary Jane Teta, Dr.P.H. Director of Epidemiology, Health information, Risk Assessment and TSCA , Union Carbide Corp., and Adjunct Associate Professor of Epidemiology and Biostatistics, University of Massachusetts, Danbury, Connecticut, USA.
She went into partnership with Dennis Paustenbach in a company called Exponent and was on the Advisory Board of the HCRA
  • Erich Wichmann, M.D., Ph.D. Acting Director, GSF Institute of Epidemiology, and Director, Department of Labour Safety and Environmental Medicine University of Wuppertal Oberschleissheim, Germany
  • Gary M Williams, M.D. Director of Medical Sciences and Chief, Division of Pathology and Toxicology, American Health Foundation, and Research Professor, Department of Pathology, New York Medical College, Valhalla, NY, USA
  • Ernst L Wynder, M.D.* President, American Health Foundation (AHF), and Clinical Professor, Department of Community and Preventive Medicine , New York Medical College , Valhalla, NY, and Adjunct Member, Memorial Sloan-Kettering Cancer Center, New York, NY, USA
* Co-Chair of Workgroup on Hazard Identification and Member of Organizing Committee. Wynder's later inclinations to help the tobacco industry is still in dispute. He was an anti-smoking activist early in his career, but later his AHF relied on cigarette company grants.

London Principles http://www.fedfocus.org/science/london.html

Expert Panel http://www.fedfocus.org/science/london-panel.html

[The organisation was actually from Philip Morris, via Jim Tozzi at Federal Focus/Multinational Business Systems, with the help of George Carlo. The vast majority of these 'experts' were science-for-sale consultants to the tobacco and chemical industries.]


1995 Oct On London Principles panel http://legacy.library.ucsf.edu/tid/aqp05c00/pdf



1995 Dec: The Harvard Center for Risk Analysis (run by John Graham) lists the following companies as providing grants (as distinct from the main funders of projects -- a list which included Carlo's own Health and Environmental Services Group):

3M, Aetna Life & Casualty Company, Alcoa Foundation, American Automobile Manufacturers Association, American Crop Protection Association, American Petroleum Institute, Amoco Corporation, ARCO Chemical Company, ASARCO Inc., Ashland Inc., Astra AB, Atlantic Richfield Corporation, BASF, Bethlehem Steel Corporation, BP America Inc., Chemical Manufacturers Association, Chevron Research & Technology Company, CIBA-GEIGY Corporation, The Coca-Cola Company, Cytec Industries, Dow Chemical Company, DowElanco, Eastman Chemical Company, Eastman Kodak Company, Edison Electric Institute, E.I. DuPont de Nemours & Company, Electric Power Research Institute, Exxon Corporation, Ford Motor Company, Frito-Lay, General Electric Fund, General Motors Corporation, Georgia-Pacific Corporation, The Goodyear Tire & Rubber Company, Grocery Manufacturers of America, Hoechst Celanese Corporation, Hoechst Marion Roussel, ICI Americas Inc., Inland Steel Industries, International Paper, Janssen Pharmaceutica, Inc., Johnson & Johnson, Kraft General Foods, Mead, Merck & Company, Mobil Oil Corporation, Monsanto Company, New England Power Service, Olin Corporation, Oxygenated Fuels Association, PepsiCo Inc., Pfizer, Procter & Gamble Company, Rhone-Poulenc, Inc., Rohm and Haas Company, Shell Oil Company Foundation, Texaco Inc., Union Carbide Corporation, Unocal, USX Corporation, Westinghouse Electric Corporation, and WMX Technologies, Inc.



1996 Nader's Public Citizen report on John D Graham says:

Graham told political strategists at the Heritage Foundation that "I don't think there's any more passionate advocate of regulatory reform than myself" and that "environmental regulation should be depicted as an incredible intervention in the operation of society."

He has said that support for the regulation of chemicals in our water supply shows the public's affliction with "a syndrome of paranoia and neglect."

According to news reports, Graham also explained to attendees at a conference at Duke University in 1996 that he believed that "government agencies should be required to depend on expert analyses, rather than public views, in deciding which threats to regulate." [53]

1996 Jan 31 Making Regulatory Reform a Reality, Heritage Foundation Reports: A Heritage Foundation Symposium; [2]

 [3]
 [4]

Must extract http://www.citizen.org/documents/grahamrpt.pdf


1996 Dec 8-12 Meeting of the Society for Risk Analysis in New Orleans, John D Graham passed the title of President ot New York University professor Rae Zimmerman. The meeting was held with International Society of Exposure Analysis (ISEA) [54]


1997 Graham advocated a sweeping requirement that would have imposed upon all risk-related determinations a "peer review" by committees likely to be staffed with industry-friendly "experts" and centralized clearance through the White House Office of Science and Technology Policy. These red tape burdens would apply even if the agency was merely publicizing information on a hazard that had not been not part of any formal rulemaking, such as a pronouncement by the Surgeon General on the risks of smoking. In short, Graham proposes a near stranglehold on the government's ability to communicate public health information.


1997 mid-year Graham announced that passenger air bags were not cost-effective in cars.

[According to government records in 2000 -- the air bags rule alone has saved 6,733 lives to that date.]

Nader's Public Citizen report says:

Graham has wildly distorted the facts when advocating industry positions in the media. For example, amid fierce controversy over defectively designed air bags in 1997, he wrongly told the Associated Press that "most" of the 38 children killed by air bags had been decapitated.

The same year, he appeared on ABC's Good Morning America to report that a Harvard Center for Risk Analysis study had found that the "cost" of passenger side air bags was $399,000 for each year of life saved.

After harsh criticism, the study was peer reviewed. When it was finally published in the Journal of the American Medical Association, Graham had flip-flopped — revising that estimate down to $61,000 per life year saved, and concluding that air bags were, in fact, a worthwhile and life-saving investment. [55]



1997 Graham serves as a "distinguished fellow" on the Public Health Policy Advisory Board (PHPAB). According to the group's tax forms, in 1997, he received $8,333 in compensation for his service and another $30,000 in 1998. PHPAB is funded primarily by industry sources such as the American Chemistry Council (formerly the Chemical Manufacturers Association), Chlorine Chemistry Council, and Procter & Gamble as well as grants from a few government agencies. [56]


1997 Mar "Junk-man" Steve Milloy took over officially as 'Executive Director' of The Advancement of Sound Science Coalition (TASSC). He had previously been hired as the 'behind the scenes contact' who could answer press questions. For a while Garrey Curruthers continued to parade himself as 'President' and 'Founder'.

The so-called Management Board listed John D Graham on the TASSC letterhead (also sometimes called an "Advisory Board" - NOT a SAB). Different listings had different names at different times -- for instance, George Carlo's name never appears on the letterhead, but he is listed by APCO (the PR company which ran the operation behind the scenes) as a member of the Scientific Advisory Board.

This Advisory Board appears to have consisted of a variable list with at least 7 well-known tobacco industry 'consultants', only a few of which were actual 'scientists':

TASSC's Scientific Advisory Board appears to have been a cabal of think-tank operators, industry supporters and professional corporate lobbyists, including:

This summary records the claim that in 1997 Milloy... 
-- launched a full-scale attack on restrictive air-quality standards, with an full-page ad in The Washington Post signed by 100 physicians and scientists.
-- released an open letter to world leaders signed by 500 physicians and scientists attacking the Kyoto Conference global warming treaty.
-- attacked the EPA for its use of guideline standards of epidemiology which are inferior to GEP.
-- held a junk-science conference in Phoenix, and a media summit on health scares at the North Carolina State University run by TASSC enthusiast Dr Robert Entman. [Entman was a professor of Journalism. TASSC had previously sponsored his report on The Role of Science in Reporting of Public Health Policy Controversies During 1995. ]
-- ran roundtable meetings for lobbyists and a series of editorial board briefings on silicone breast implants, hosted by Dr Elizabeth Connell. [She also travelled to the UK to lobby the new Labor British Health Minister.] [57]
[Elizabeth Connell was ex-FDA and Emory Uni. In 2003 she was also a senior counselor for the tort-reform advocacy group Citizens Against Lawsuit Abuse (CALA) funded by Philip Morris. This was a subsidiary of the ATRA 'tort reform/product liability' coalition also run by APCO.]

1997 Sep 12 Testimony of John D Graham before the Senate Committee on Governmental Affairs, Hearing on S. 981, "The Regulatory Improvement Act of 1997. Public Citizen reports

Graham believes that virtually any hazard-related agency action should pass through a formal review by the White House. Graham advocated a sweeping requirement that would have imposed upon all risk-related determinations a "peer review" by committees likely to be staffed with industry-friendly "experts" and centralized clearance through the White House Office of Science and Technology Policy.

These red tape burdens would apply even if the agency was merely publicizing information on a hazard that had not been not part of any formal rulemaking, such as a pronouncement by the Surgeon General on the risks of smoking.

In short, Graham proposes a near stranglehold on the government's ability to communicate public health information.

1997 Oct 20 Graham has had to return the Philip Morris cheque for $25,000, and in return they sent him $20,000 via their subsidiary Kraft. He writes to Mayada Logue of Philip Morris (not to Kraft!) thanking her for expediting the gift.

Thank you for your efforts to expedite Kraft Foods, Inc. gift of $20,000 for the Harvard Center of Risk Analysis. HCRA continues to promote a reasoned public response to health, safety and environmental risks by addressing the current issues in risk analysis. We appreciate your support and confidence in our work. Please fell free to contact me if I can ever be of assistance.


[Note this is five years after the initial Kraft, Guardia contact, and the correspondence is still with Mayada Logue at Philip Morris]



1998 In a letter to Philip Morris thanking Tom Borelli for $25,000 contribution to the Annapolis Center, Richard Rue discussed "our new RegX-pert system (an expert computer system that will allow evaluation of federal and state regulatory actions)"

As outline in an internal strategy paper, the RegX-Pert system, adopted from a system required by the Department of efense for scruitinizing weapons systems, was designed to use a series of questions applied in a repetitive way to determine the completeness of a scientific and economic analysis to be used in developing a regulation.

Informing the process was the question of whether a regulation was compliant with th cost-benefit requirement of the OMB. The RegX-Pert system was reportedly developed with input from staff of the House and Senate leadership, staff of relevant congressional committees, and former OMB staff (none of whose names were disclosed in Annapolis Center documents) The program was then reportedly reviewed by George Gray from th Harvard Center for Risk Analysis (who's head, John D Graham took control of the OMB during the Bush II Administration) and Robert Hahn from the AEI and was shared with the OMB for input and feedback. Put another way, the Annapolis Center was in the busines of developing tools to assess and interpret science for decision makers in Congress, the courts, the media, regulators and the regulators o the regulatory agencies -- that is the officials reviewing regulations at the Office of Information and Regulatory Affairs (OIRA) located within the OMB

In the late 1990s and early 2000s, a series of workshops called the Annapolis Accords was organized around a number of important themes, including risk (coordinated by John Graham from the HRCA).

<a href="http://books.google.com.au/books?id=X_vS751dIAgC&pg=PA154&lpg=PA154&dq=%22Richard+Rue%22+Annapolis&source=bl&ots=DDoP8m3wt9&sig=2_zKUr-MSQX82moEjLMP5xgplBE&hl=en&sa=X&ei=7zZ3UfHfD8uuiQfx2ICADA&sqi=2&ved=0CFQQ6AEwBw#v=onepage&q=%22Richard%20Rue%22%20Annapolis&f=false" target=tobdocs> <img src="../library/seeArticle.jpg" align=right> </a>


1998 Jan TASSC Advisory Board in 2065254885 (19980818)


1998 Feb 17 Borelli being billed $5,000 for a dinner honouring John Graham 2073684240


1998 Jun Graham and two others from the Society for Risk Analysis wrote to Thomas Borelli of Philip Morris on HCRA letterhead to solicit $50,000 of a total funding schedule of $250,000 for an international symposium in Brussels. The Society for Risk Analysis posted an Internet list of corporate "sustaining members" that includes Amoco, the Chemical Manufacturers Association, Chevron, DuPont, Exxon, Procter & Gamble and the Sapphire Group, which is made up of chemical, cosmetic, food and health care interests.. [Public Citizen exposè ]


1999 WHO and the US Cellular Telephone Industry Association ran a symposium on "EMF Risk Perception and Communication". It was organised by long-term EMF-problem denier, Michael Repacholi (Department of Protection of the Human Environment - Australian EMF lobbyist) and had support from the Australian and Canadian radiation protection, telephone industry, and hydro-power companies.

Among the industry people involved were:

  • Prof John D Graham, Harvard Center for Risk Analysis, Harvard School of Public Health, Boston, MA, USA
  • Dr Dan Wartenberg, Environmental and Occupational Health Sciences Institute, Pisscataway, NJ, USA.
  • Mr Michael Dolan, Assistant Director and General Counsel, EMF Advisory Group, ESAA Ltd., Melbourne, Victoria, Australia

Possible health effects of exposure to electromagnetic fields (EMF) have led to concerns among the general public and workers that appear to go well beyond those that are attributed to well-established risks. It is necessary to understand why this occurs and to deal with it through an effective communications programme. People have the right to access reliable, credible and accurate information about any health risks from EMF exposure. However, recent history has shown that, communication among scientists, governments, industry and the public, has often been ineffective. There continues to be a divergence of views because of this failure to communicate effectively.

Repacholi was saying that, obviously the problem is not with EMF exposure, but with the industry's failure to "communicate effectively" with the cellphone-using public. This is followed by a dissertation on risk analysis. John D Graham then made a keynote address "Making Sense of Risk: An Agenda for Congress" which begins with the old familiar cry:

The American people are suffering from what can be called "a syndrome of paranoia and neglect" about potential dangers to their health, safety, and the environment. This leads to a paradox that is becoming increasingly recognised. Large amounts of resources are devoted to slight or speculative dangers while

substantial and well-documented dangers remain unaddressed.

To avoid "paralysis of analysis," Congress should authorise agencies to tailor the intensity of analysis to the importance and complexity of the specific problems.

According to Graham's record over the years, the regulatory activities which should have been ignored, are such trivialities as lead in petrol, DDT and general pesticide residues on fruit, soil and groundwater contamination in many abandoned hazardous waste sites, benzene, chloroform in drinking water, saccharine, car fuel economies, tobacco smoke, and EMF's potential problems. This is the paranoid side of his equation.

They should concentrate instead on the positive side, promoting low-fat diets, physical exercise, smoke detectors, vaccination, and seat belts in cars. Apparently there has been some bureaucratic failure to get such messages across!

These are all major public health problems that receive less than their fair share of attention in media stories and public policy.

The key to the risk assessment profession's philosophy is contained in the paragraph:

  1. First, Congress should compel agencies to make use of the best available scientific information.
  2. Second, when scientific knowledge about risk is imperfect or deficient Congress should require agencies to employ probabilistic methods of uncertainty analysis.
  3. Third, when the same hazard poses more danger to some citizens than others, Congress should insist that agencies report that information through distributional methods of variability analysis
  4. Fourth, to nurture the public's sense of perspective about risk, Congress should require agencies to make thoughtful use of risk comparisons.
And of course we know who determines all of this; economists with a Decision Sciences degree who are able to calculate the society's cost-benefit ratios for regulatory actions.

Congress needs to insist that value judgements about proper margins of safety be made by accountable regulators and not be buried in the choice of particular assumptions or models used to compute risk.

Which completely ignores the extraordinary range of assumptions and models used by risk assessors, who hope to take over the decision-making from the biomedical and environmental professions at the EPA, OSHA, and FDA.
[This document has some other material worth reading if you are interested in layman's EMF's risk perception. However, why no one studies the risk-perception of those scientists active in the EMF-health research field, is a question that only the WHO or the US Congress could really answer] [58]

1999 Mar 11 The Weinberg Group (a notorious scientific recruitment company run by Myron Weinberg) is recruiting speakers and sponsors for a Philip Morris Research Center (secret) conference. Obviously Philip Morris do not want their involvement to be known. His Weinberg letter/contract spells out that:

The next phase of the proposed program involves identifying and recruiting :
(1 ) an overall sponsor for a two-day meeting on evaluating proposed changes in cigarette design ;
(2) a sponsoring institution and locale for the meeting...

Our first steps will involve attempting to recruit an overall sponsor and a sponsoring institution for the meeting. Our primary target sponsor for the meeting is the Massachusetts Tobacco Control Program (MTCP) , with direct participation in the meeting by Dr Gregory Connolly, Director of the Program. We will attempt to enlist the MTCP's participation through contacts with Dr Connolly.

Our primary target sponsoring institution is Harvard University; we will attempt to enlist Harvard through contacts with Dr John D Graham at the Harvard Center for Risk Analysis [HCRA]. We do not intend to recruit potential meeting participants, including an "opener" and "closer', until an appropriate sponsor and sponsoring institution are in place.

Currently, we anticipate proposing Louis Sullivan, Roger McClellan, Gilbert Omenn, and Gary Williams as potential "openers," and Neil Benowitz as a potential "closer." If we can obtain agreement from Dr Connolly on our proposed "closer" we will begin discussions with Dr Benowitz concerning his potential participation in the meeting. However, we will not begin to recruit other potential participants prior to discussions with you concerning proposed options and strategies. [59]


1999 Apr One monthly issue of Risk in Perspective from the HRCA was titled, "Toxic Pollution from Power Plants: Large Emissions, Little Risk."


1999 Apr 29 Testimony of John D. Graham before the Senate Committee on Regulatory Affairs on S. 746, Although his testimony specifically criticized regulatory programs affecting the gasoline additive MTBE, fuel economy standards, and the controversy over passenger-seat air bags, he did not identify any of the funders of his Center.


2000 Nader's Public Citizen report on John D Graham and the HCRA says:

Graham is currently the director of the Harvard Center for Risk Analysis (HCRA), which is connected to Harvard University as a separate sub-unit of the Harvard School of Public Health.

The Center offers some twelve courses in a field called "decision analysis" to Harvard students but does not itself grant degrees.

In addition to the student courses, the Center also offers, at a fee, short courses and multi-day seminars that grant "continuing executive education" credits to corporate officers. Graham teaches several of the courses, which train business executives to, among other things, ""identify subgroups of lay people who are likely to be particularly outraged or tolerant about a potential risk."

The Center also publishes a monthly newsletter called Risk in Perspective. One recent issue suggested that "speculative, minor" risks to children include pesticides, Bisphenol-A and phthalates (toxic chemicals found in plastics and some children's toys), without acknowledging that funders of HCRA make these products. Another issue of the newsletter from April 1999 was titled, "Toxic Pollution from Power Plants: Large Emissions, Little Risk." [60]

2000 John D Graham of Harvard Center for Risk Assessment was enlisted as a member of the Environmental Protection Agency's first (1994) and second (2000) Science Advisory Board on the risk assessment on dioxin. He downplayed the risks.

The National Public Radio report containing Graham's comments [critical of the EPA findings] failed to mention his position on the Science Advisory Board and failed to disclose that his Center is supported by money from 48 different dioxin producers, including incinerator companies, pulp and paper companies, cement kilns, copper smelters, PVC manufacturers, PCB producers and the petroleum industry.

Graham's tight connections to the chemical industry have also influenced his legislative work. Graham spoke at a panel discussion held around 1994 at the Chemical Industry Institute of Toxicology (CIIT) alongside executives from Eastman Kodak, the ppAmerican Industrial Health Council[[, Air Products and Chemicals, E.I. DuPont de Nemours, and the Chemical Manufacturers Association (now called the American Chemistry Council). [61]


2000 Jun Nader's Public Citizen reported that ...

... Graham was a member of the EPA Science Advisory Board that reviewed the agency's risk assessment on dioxin, an industrial contaminant, in 1994 and 2000.

In June 2000, the EPA announced a draft of its study, which showed that exposure to the level of dioxin currently in our environment causes an increase in the average American’s lifetime cancer risk to as high as 1 in 100. The EPA’s reassessment also found that dioxin, even at very low levels of exposure, is linked to infertility, immune system damage and learning disabilities.

But rather than acknowledging that dioxin poses an additional threat to human health, in his comments to the media Graham misleadingly downplayed the risk by comparing the EPA’s findings to other types of risks, such as the risk of dying in a car crash. When compared with these risks, Graham suggested, the risk posed by dioxin appears "normal."

The National Public Radio report containing Graham’s comments failed to mention his position on the Science Advisory Board and failed to disclose that his Center is supported by money from 48 different dioxin producers, including incinerator companies, pulp and paper companies, cement kilns, copper smelters, PVC manufacturers, PCB producers and the petroleum industry.

[Public Citizen expose] [62]


2000 Jul As many cities and states were considering outlawing the use of cell phones while driving, Graham published a study (funded by AT&T Wireless Communications for $300,000) assessing the risks. The study came out against any ban on using cellular phones while driving -- concluding that such a ban would be more costly than air bags and that there was "not enough reliable information on which to base reasonable policy."

As Tom and Ray Magliozzi, hosts of Car Talk from National Public Radio put it in response to a similar study by Robert Hahn, Graham’s intellectual and political ally at the American Enterprise Institute-Brookings Joint Center for Regulatory Studies, "This seems to us to be a clear case of cost/benefit analysis run amok." [Public Citizen expose] [63]


2000 Nov ELECTION OF PRESIDENT GEORGE W BUSH. Graham is now administrator of the Office of Information and Regulatory Affairs (OIRA) which has long been the White House control over the health and environmental agencies and their regulations.


2000 Dec (2004 Aug 15 Analysis piece in Washington Post, says:) Lobbyist Jim Tozzi (ex head of the OIRA under Reagan) was a major behind-the-scenes architect of the Data Quality Act (DQA) which he helped to become law in December 2000 as a stealth rider to the Treasury and General Government Appropriations Act for Fiscal Year 2001.

The Data Quality Act -- written by an industry lobbyist and slipped into a giant appropriations bill in 2000 without congressional discussion or debate -- is just two sentences directing the OMB to ensure that all information disseminated by the federal government is reliable. But the Bush administration's interpretation of those two sentences could tip the balance in regulatory disputes that weigh the interests of consumers and businesses.

John D. Graham, administrator of the OMB Office of Information and Regulatory Affairs (OIRA), who has directed implementation of the Data Quality Act, said the law will keep the federal government hewing to "sound science." He said the act, which allows people and companies to challenge government information they believe is inaccurate, is equally accessible to "a wide diversity of interests, both in the business community and in the consumer, environmental and conservation communities."

But many consumers, conservationists and worker advocates say the act is inherently biased in favor of industry. By demanding that government use only data that have achieved a rare level of certainty, these critics maintain, the act dismisses scientific information that in the past would have triggered tighter regulation. [64]

2001 Nov Dioxin safety: But now there are more hurdles. A subcommittee of an EPA scientific advisory panel composed of outside experts publicly convened in November for two days to review the agency's findings and to make recommendations.

About a third of the 21 panel members were scientists and scholars who have worked as paid consultants to the chemical industry. They included

  • John D. Graham -- long a critic of the notion that dioxin and cancer are linked and founder of the industry-backed Harvard Center for Risk Analysis -- who was recently appointed to a key regulatory review post in the Office of Management and Budget, and
  • Dennis Paustenbach, vice president of Exponent Inc., an engineering and scientific consulting firm. Paustenbach's firm has advised Chemical Land Holdings Inc. and Occidental Chemical Corp. on ways of challenging the EPA's dioxin findings.

[65]


2001 Jan See Public Citizen "Graham's Nomination to Head OMB-OIRA Threatens Health Safety and Environemental Safeguard" and their critique of "Put Economists in Charge of Regulatory Scientists" [66]


2001 Feb A proposal related to the role of cost-benefit analysis in protective regulations, was soundly rejected by a unanimous Supreme Court in a February 28, 2001 decision.

The American Trucking Associations sued the EPA to block new requirements issued under the Clear Air Act. Graham and other anti-regulatory "economists" from the American Enterprise Institute-Brookings Joint Center for Regulatory Studies (AEI-Brookings) submitted a brief to the Court on the side of the trucking industry, arguing that requiring cost-benefit analysis by the EPA would "improve regulatory decision-making."

Justice Scalia, writing for the full Court, held that neither the Clean Air Act nor the U.S. Constitution requires that corporate compliance costs be considered when EPA writes a rule to protect health and the environment. Even Bush II's new head of the EPA, Christine Todd Whitman, supported the Supreme Court's decision, calling it "a solid endorsement of EPA's efforts to protect the health of millions of Americans from the dangers of air pollution."


2001 Mar Article by Derek Yach in American Journal on Public Health "Junking Science to Promote Tobacco"

One prestigious US institution that has received funds from Philip Morris and its subsidiaries is the Harvard Center for Risk Analysis, whose former director, John Graham, has assisted Philip Morris with risk communication about environmental tobacco and a restricted grant from the Risk Science Institute of theInternational Life Sciences Institute (ILSI).

On 6 March 2001 President Bush nominated John Graham to be administrator of the Office of Information and Regulatory Affairs of the Office of Management and Budget.

This office reviews and approves-- or blocks -- all major federal regulations. The consumer advocacy group Public Citizen criticized the nomination on the basis of the links between Graham and corporate funding. [67]

HCRA page [68].

Public Citizen attack http://www.citizen.org/ congress/regulations/graham.html


2001 Mar 5 Nader's Public Citizen attack on Graham's elevation to the position as 'regulatory czar' as head of the OIRA which was within the Office of Management & Budget (OMB) in the Bush II White House.

If Graham is approved by the U.S. Senate for Office of Information and Regulatory Affairs (OIRA)Director, he will be in the catbird seat; overseeing the entire executive regulatory process.

Under a standing Executive Order, a primary function of the OIRA is to "review" cost-benefit calculations produced by federal agencies before new standards and rules can be issued. In theory, the OIRA director should serve as an honest broker, reviewing regulatory proposals from federal agencies and deferring to agency expertise on most technical and scientific matters.

However, the OMB's "review" process has been used in the past to block the issuance of key health and safety standards. During the Reagan-Bush I years, political appointees within OMB, in conjunction with councils run by Vice President Bush and Vice President Quayle, were given broad discretion to review and block new standards created by federal agencies, often at the direct request of chemical companies, auto manufacturers and other regulated interests.

As this report shows, debates over the safety of pesticides, injury prevention, pollution, second-hand smoke, toxic chemicals and contamination of our food and water have all been victims of these efforts.15 If Graham goes to the OMB, he could serve as the back-door conduit for a new corporate assault on public and environmental health. [69]

2001 Jun Public Citizen: "John Graham Nomination Confirmed" -- an excellent overview and index to many Graham and HCRA documents and articles. [70]


2001 Jul 21 Washington Post article "Graham Flunks the Cost Benefit Test" by Dick Durbin. [71]


2003 Dec 11 Crimes Against Nature by Robert Kennedy Jr.

Bush's Environmental Protection Agency has halted work on sixty-two environmental standards, the federal Department of Agriculture has stopped work on fifty-seven standards, and the Occupational Safety and Health Administration has halted twenty-one new standards. The EPA completed just two major rules -- both under court order and both watered down at industry request -- compared to twenty-three completed by the Clinton administration and fourteen by the Bush Sr. administration in their first two years.

This onslaught is being coordinated through the White House Office of Management and Budget -- or, more precisely, OMB's Office of Information and Regulatory Affairs, under the direction of John Graham, the engine-room mechanic of the Bush stealth strategy. Graham's specialty is promoting changes in scientific and economic assumptions that underlie government regulations -- such as recalculating cost-benefit analyses to favor polluters. Before coming to the White House, Graham was the founding director of the Harvard Center for Risk Analysis, where he received funding from America's champion corporate polluters: Dow Chemical, DuPont, Monsanto, Alcoa, Exxon, General Electric and General Motors.

Under the White House's guidance, the very agencies entrusted to protect Americans from polluters are laboring to destroy environmental laws. Or they've simply stopped enforcing them. Penalties imposed for environmental violations have plummeted under Bush. The EPA has proposed eliminating 270 enforcement staffers, which would drop staff levels to the lowest level ever. Inspections of polluting businesses have dipped fifteen percent. Criminal cases referred for federal prosecution have dropped forty percent. The EPA measures its success by the amount of pollution reduced or prevented as a result of its own actions. Last year, the EPA's two most senior career enforcement officials resigned after decades of service. They cited the administration's refusal to carry out environmental laws.

The White House has masked its attacks with euphemisms that would have embarrassed George Orwell. George W. Bush's "Healthy Forests" initiative promotes destructive logging of old-growth forests. His "Clear Skies" program, which repealed key provisions of the Clean Air Act, allows more emissions. The administration uses misleading code words such as streamlining or reforming instead of weakening, and thinning instead of logging. [72]

2004 Microwave News says that Graham's Harvard Center for Risk Analysis (HCRA) got "more than $419,000 from Carlo so that his Wireless Technology Research (WTR) would have a veneer or respectability" p11 [73]

[This would have been channeled through Carlo's operations from the Cellular Telephone industry Association (CTIA) who funded WTR.]



2004 Aug Graham is now working with ORIA on Data Quality Act, see p17 5001007651/5001007672 Tozzi praises


2010 Feb 6 Microwave News criticises a recent report Risk Governance Deficits: An Analysis and Illustration of the Most Common Deficits in Risk Governance by the Geneva-based International Risk Governance Council (IRGC) on the grounds of conclict of interest.

The IRGC is a self-described "independent" group run by a group of government, industry and academic leaders. The report has case studies on hot-button issues, including genetically modified food, mad-cow disease, and EMFs (cellphone radiation). Most are relatively sensible, it says, but the one on EMF's is not:

One of the four principal authors of the IRGC report is John Graham, who is himself a controversial figure in the risk business. He was the founder of the Harvard Center for Risk Analysis, whose corporate sponsors read like a roster of the S&P 500.

More surprising is that the chair of the IRGC's Scientific and Technical Council is Granger Morgan of Carnegie Mellon University (CMU). Morgan was a coauthor of an influential EMF report back in 1989 —the first to introduce the concept of precaution for EMF health risks; they called it "prudent avoidance." (One lesser known fact: Morgan was Graham's thesis advisor at CMU.)

Graham is no stranger to EMFs either. He provided cover for George Carlo's research project for the cell phone industry. Carlo paid Graham's Center for Risk Analysis over $400,000 to help him camouflage the fact that Carlo's enterprise, known as WTR (Wireless Technology Research), was a scam, whose primary objective was to avoid doing health research.

Search for IRGC at <a href="http://www.microwavenews.com">Microwave News. </a>


2005 Oct Graham left President Bush II's Office of Management and Budget

John D. Graham , the cost-benefit champion who left in October ... also served as an adviser to Mercatus, the staunchly anti-regulatory center funded largely by Koch Industries Inc., the oil and gas company and mega-GOP contributor. Charles G. Koch and another top Koch official serve on the nine-member Mercatus board of directors.

In the early days of President Bush's first term, when the OMB asked for public input on which regulations should be revised or killed, Mercatus submitted 44 of the 71 proposals the OMB received. And the OMB approved 15 of them, the National Journal reported at the time.

These recommendations critiqued onerous regulations such as a proposed Interior Department rule prohibiting snowmobiles in Rocky Mountain National Park; a Transportation Department rule limiting truckers' hours behind the wheel; and that silly EPA rule limiting the amount of arsenic in drinking water. (Hey! You don't want it? Don't drink it.)

The Ralph Nader-founded Public Citizen uncharitably calls Mercatus a "wholly-owned subsidiary of Koch industries and other corporate interests." Koch (pronounced "coke") has given many millions to Mercatus, but other companies also have contributed a bit as well. Over the years, those contributors have included Fannie Mae, Microsoft, Pfizer and Enron, which have donated about $50,000, plus $10,000 from the late Kenneth L. Lay and his wife's foundation.

According to the Center for Public Integrity, Koch money controls or strongly influences a number of leading conservative institutions, including the Cato Institute (co-founded by Charles Koch), the Tax Foundation, the Institute for Justice, the Federalist Society, and Citizens for a Sound Economy, which was founded in 1984 by Charles and David H. Koch and Koch executive Richard Fink.

[74]