When Certainty Becomes a Weapon: How Transparency Rules Could Undermine Public Health Science
On May 23, 2025, the White House released a new executive order titled "Restoring Gold Standard Science." Framed as a reaffirmation of transparency in scientific policymaking, the order lays out expectations on how federal agencies must handle scientific information, data disclosure, peer review, and the integration of research into public policy.
The executive order outlines a series of principles that, at first glance, may seem commendable. It insists that federal agencies should:
Use science that is reproducible, falsifiable, peer-reviewed, and free from political interference.
Publicly disclose the data and models behind scientific conclusions used in regulation, unless doing so would violate the law.
Use weight-of-evidence frameworks that reflect a broad view of available research, and explicitly account for uncertainty in modeling.
But as the political and scientific communities dig into the substance of the order, many are asking a crucial question: is this truly an assertion to uphold scientific integrity, or a repackaged attempt to weaken regulatory science in favor of ideology and industry?
A New Name for an Old Rule
Central to the order is a revived version of what scientists have long criticized as the Secret Science Rule. First proposed under the Trump administration in 2018, the rule was ultimately rejected by courts and the Biden administration. It required that only studies with publicly available data could be used in regulatory decision-making. At the time, leading organizations like the American Association for the Advancement of Science pushed back, arguing that this rule ignored foundational principles of research ethics, especially in studies involving human subjects.
The 2025 order echoes those same demands under a new banner of "transparency." If implemented strictly, it could bar agencies like the EPA, FDA, and CDC from using landmark public health research, particularly epidemiological studies that involve marginalized communities, children, or long-term human observation. These studies often include data that cannot ethically or legally be made public, such as medical records or personal identifiers.
What Are Epidemiological Studies and Why Do They Matter?
To understand the stakes, it’s important to define what epidemiological (epi) studies are, and how they differ from bench science. While bench science is conducted in controlled lab settings, isolating variables and testing hypotheses under tightly regulated conditions. Epidemiology observes patterns, causes, and effects of health and disease in human populations. It draws from real-world data, with some types of studies over long periods, to identify risks, test public health interventions, and validate scientific theories.
Despite the complexity of studying human populations, epi researchers use rigorous statistical methods to control for confounding variables, such as age, socioeconomic status, or co-existing health conditions to ensure that observed associations are as reliable and meaningful as possible.
Epi studies reflect human lived experience, capturing how scientific phenomena play out in actual communities. They have been instrumental in identifying the health risks of smoking, lead exposure, air pollution, and more. In one instance, the tobacco industry has attacked epi studies for the same reasons now being repackaged as "gold standards", arguing they weren’t reproducible or precise enough to inform regulation.
History tells us: when powerful interests seek to limit which science “counts,” it’s often because the evidence threatens their bottom line.
Uncertainty Isn’t a Flaw, It’s Part of the Process
Much of the executive order’s language hinges on eliminating “unwarranted certainty.” But what does that really mean?
To the public, uncertainty often suggests confusion or a lack of knowledge. To scientists, uncertainty is a measure of how well something is known, a formal acknowledgment of complexity, not a sign of weakness. In fact, scientific rigor depends on understanding uncertainty: measuring it, reducing it, and transparently communicating its implications.
Epidemiologists are especially familiar with uncertainty. They routinely work with incomplete or evolving data and use statistical tools to quantify margins of error, estimate confidence intervals, and test the robustness of their models. This isn’t sloppy science, it’s how public health decisions are responsibly made in the real world.
As the Union of Concerned Scientists puts it:
“Uncertainty is a natural part of science. It does not mean we know nothing, only that our knowledge is incomplete. Scientists express uncertainty as a range of possible outcomes, and still provide decision-makers with valuable guidance.”
Acting Amid Uncertainty
The central paradox is this: policymakers must act even when science can’t offer 100% certainty. If we waited for definitive proof in every case, we would have no clean air laws, no tobacco restrictions, no vehicle safety regulations, no vaccines, and no climate policy.
Regulatory science operates under a different standard than pure research. It doesn’t aim for perfect knowledge, it aims to protect human health and safety based on the best available evidence. Precautionary action isn’t unscientific; it’s a moral and practical imperative.
Yet the language of the 2025 executive order could enable agencies to sideline valuable science not because it's invalid, but because it’s inconvenient, too uncertain, too messy, or too politically charged. And by framing those studies as “non-reproducible” or “methodologically insufficient,” the order opens the door to cherry-picking evidence that aligns with predetermined policy goals.
What’s at Stake
The Restoring Gold Standard Science order isn’t just a bureaucratic update. It’s a statement about what kinds of science are allowed to guide federal policy, and which are not. It raises urgent questions about who gets to define scientific rigor, and whether we’re willing to dismiss the very studies that have protected public health for decades.
Science isn’t perfect. But when uncertainty is weaponized to paralyze action or disqualify inconvenient evidence, we risk turning a tool of humility into a political bludgeon. Instead of embracing science’s complexity, the order demands a false simplicity… one that could cost lives.
This article was written by Elizabeth Sharp, CEHN intern.