The 1947 letter from a DuPont medical director to the medical director of Calco Chemicals opens with a plain sentence: “Of the original group, who began the production of this product, approximately 100% have developed tumors of the bladder.” The product was beta-Naphthylamine. Total enclosure of the production line at DuPont’s Chambers Works was not completed until 1951 — thirty years after production began with full knowledge of the danger. This is the kind of document that fills Doubt Is Their Product: How Industry’s Assault on Science Threatens Your Health (Oxford University Press, 2008): internal corporate correspondence, buried studies, and regulatory records establishing that the companies producing asbestos, benzidine, tetraethyl lead, vinyl chloride, chromium 6, beryllium, benzene, diacetyl, and dozens of pharmaceutical products knew — often for decades — what their products were doing to the workers who handled them and the consumers who used them, and chose concealment over disclosure.
David Michaels writes from inside the regulatory apparatus. He served as Assistant Secretary of Energy for Environment, Safety, and Health under Clinton, where he ran the process that established a stronger workplace rule for beryllium exposure and shepherded through Congress the compensation program for civilian nuclear weapons workers — a program that has now paid more than three billion dollars to workers made sick by beryllium, radiation, and other exposures at Manhattan Project and Cold War facilities. He is an epidemiologist by training whose prior research contributed to the scientific literature on asbestos and lead. He now directs the Project on Scientific Knowledge and Public Policy at the George Washington University School of Public Health. The book draws on documents he obtained through his own bankruptcy-court digging, litigation discovery he participated in, and internal records from industries he confronted as a regulator. His account of what he saw at close range is documented in a footnote apparatus that runs hundreds of entries.
Publication in 2008 followed seven years in which the Bush administration institutionalized many of the strategies the book documents. Federal scientific advisory committees had been stacked with industry consultants — the CDC’s childhood lead poisoning prevention panel was reconstituted to include a scientist whose work was funded by a metals smelter facing large clean-up costs. Philip Cooney, formerly a lobbyist at the American Petroleum Institute working as chief of staff at the White House Council on Environmental Quality, was editing federal climate reports to insert the word “significant” before “uncertainties.” Two paragraphs slipped into a 2000 appropriations bill by a former Reagan-era Office of Management and Budget official who had also consulted for Philip Morris — the Data Quality Act — had given every regulated industry a formal procedure to challenge and demand revision of federal scientific documents. OSHA had issued workplace standards for two new chemicals in ten years. The FDA’s Center for Drug Evaluation and Research had approved Vioxx on the strength of Merck’s own studies. Between 88,000 and 139,000 heart attacks followed, according to the FDA’s own scientists, before the drug was withdrawn.
Michaels is a convergent witness — an establishment-trained epidemiologist and regulator whose documentation of what industry has done to workers and consumers arrives at conclusions readers of this publication will recognize, even where his framework and vocabulary remain conventional. He shows that the strategy of manufacturing scientific uncertainty was refined by Big Tobacco in the 1950s under the guidance of Hill and Knowlton, has been executed by a specialized “product defense industry” — ChemRisk, Exponent, the Weinberg Group — that moves the same consultants from tobacco to asbestos to chromium to pharmaceuticals, and now operates through a structural asymmetry in which federally funded scientists must release their raw data under the Shelby Amendment while ninety-five percent of chemical manufacturers’ toxicity submissions to the EPA are sealed as “confidential business information.” The full summary that follows walks through the case studies chapter by chapter — the aromatic amine bladder cancers, the beryllium taxicab standard, the popcorn workers whose lungs were destroyed by diacetyl, the Vioxx trial Merck engineered to reverse the finding of harm into a claim of benefit — and closes with the twelve reforms Michaels proposes to restore integrity to a regulatory system that has, in his account, largely stopped functioning.
There is a limitation worth naming, and it shapes how the book should be read. Michaels frames the institutionalization of manufactured uncertainty as a Bush-era Republican pathology, and he treats the anthropogenic climate position and the mainstream pharmaceutical-regulatory framework as settled science against which industry denial is measured. Manufactured doubt is a bipartisan product — Big Tobacco perfected it under Democratic and Republican administrations alike, and the pharmaceutical companies whose clinical-trial manipulations he documents so precisely operate under both parties without difficulty. The same institutional consensus-manufacturing machinery Michaels identifies at work in tobacco, chromium, and beryllium also produces the climate and virology positions he accepts uncritically. That the sharpest documentarian of manufactured doubt cannot see this operation running in the fields where his own priors are engaged is the strongest possible evidence for the thesis he came to prove. The 1947 letter is dated. The signature is on it. Approximately 100% of the original production group had developed tumors of the bladder. The document exists and says what it says.
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