Environmental Sampling Bias & Conflicts of Interest: The Roll of Third Party Sampling.

"To know the true reality of yourself, you must be aware not only of your conscious thoughts, but also of your unconscious prejudices, bias and habits." 

- Unknown Author

 
Part of the development of any sampling strategy is the evaluation of the scientific benefit of the collection of each potential sample to be collected.  The scientific benefit of each sample collected should be evaluated against the cost to collect that sample.  A "cost benefit analysis" is performed (or should be) for each sample collected and for every parameter proposed.  Now, this "analysis" doesn't have to be in the form of a formal document prepared for each sample detailed down to the penny the value of the data collected. It can be as simple as a mental exercise using one's best professional judgment as to which samples make the most sense and provide the most useful data without sampling everywhere for everything as if cost was not an issue.  Financial limitations should always be a point of consideration when it comes to evaluating the sampling plan. 

There is no doubt that financial considerations enter into most sampling schemes.  However, the question is whose finances are being considered?  I'm talking about bias and conflicts of interest rooted in financial considerations.  Bias and conflicts of interests in science are rarely discussed.  Scientists all like to believe that they can draw a distinct line between a scientific decision and financial decision.  However, Scientists are human and humans have bias whether they like to believe it or not.  




Its simple psychology
When a person is in a position to make a choice and one option benefits them in some way and the other option will have an adverse affect on them, its simple psychology that the person will likely pick the option that benefits them.  Not all of life's examples are that simple and clear cut, but the point remains. When a person benefits, whether financially or otherwise, the person has bias whether they recognize it or not.

Wanting your own son or daughter to win a competition is an example of bias. Perfectly natural and most people would think it would be unusual if you didn't want your own child to win. However, most people would also think it would be unfair, or a "conflict of interest" for you to be a judge or referee in your own child's competition. Now, some people may be able to be impartial while judging their own child, however, the simple potential for bias will turn most people off to that situation and the temptation to be biased may be too much for some people to overcome.  We all like to think we "could be" fair but the reality is we likely won't be.  The closer the benefit of one option is to the individual and the higher the value placed on that benefit, the less likely the person is able to be unbiased. 



Bias by Design
Different types of businesses try to bias our purchasing decisions through incentives or rewards and the simple fact is, it works. For instance, many airlines and hotels have designed programs that offer "miles" or "points" which can be redeemed for future purchases.  Many of these items are purchased using business accounts, but the program is designed to have the "rewards" applied to a personalaccount (free hotel rooms or free flights).  "Free airline tickets for me, when I spend my companies money."  Is this a problem?  Potentially, if you're spending more of your businesses money on one option just to receive the benefit for yourself. These incentive programs are designed to bias the business decision of the individual and clearly work or they would not have existed for over 20-plus years.  People respond to incentives whether they are aware of it or not.

Pharmaceutical companies have discoveredthe power of incentives in influencing (or biasing) prescription drug decisions.  Many pharmaceutical companies have historically offered "educational" incentives to Doctors prescribing their brand of a pharmaceutical drug.  These incentives came in the form of trips to desirable destinations and events or even direct cash payments in the form of "consulting fees" for patient or Doctor "education".  Recent federal legislation has largely put a stop to this kind of practice but loop holes in the regulations still exist.  We would like to think that our Doctor has only our health in mind when it comes to our medical and prescription decisions, but Doctors are subject to the same prejudices, bias and temptations as the rest of us.
 
Environmental Industry - Is there Bias?
Basically, if there are humans involved there is bias, or at least the potential for bias.  Professional environmental associations and organizations typically address the issue of bias and conflicts of interest in one way or another.  In addressing these issues they, 1) obviously acknowledge that there is the potential for a conflict of interest, and, 2) discuss the need for disclosure of the conflict, when there is one.

The more money involved in a purchasing decision, the higher the potential for a conflict.  The pressure to stay "billable" is greater than ever.  In today's tight market and the scarcity of work, the temptation to "sneak an extra cookie from the cookie jar" can be tempting. Not having work to do this week can mean not having a job next week.    

How to Overcome Bias and Conflicts
In response to these and other pressures, many groups and agencies have a minimum dollar figure at which proposed work or purchases must be competitively bid. That is, if it's below a certain dollar amount they may proceed without soliciting competitive proposals.  Above the set amount, they must solicit a certain number of competitive bids.  We have all heard of "no bid contracts" and the public perception issues they raise.  The competitive bidding process and the requirement for it is designed to keep recommendations scientific and also to assure that spending on the good or service reflects the true current market value.

Many state programs with funds set aside for clean-up projects have requirements for the solicitation and documentation of the competitive bidding process built into the program.  If you're going to receive money from the program you have to bid out the various phases of the project.  Many states programs go even further and build a virtual wall between the Project Manager (PM) and the work recommended by the PM.  That is, the PM Company is prohibited from actually bidding on or performing the work that they recommend and oversee.  The reasoning for this set up is to remove bias in the PMs recommendations.  The PM is not tempted to recommend more work than needed to create work for his company because his company doesn't actually benefit from performing the work. 

Many industries have built in third party performance or third party verification system as Standard Operating Procedures.   Asbestos removal guidelines in many states have a requirement for third party sampling and verification of the completion of an abatement project.  The company that does the removal can't collect its own verification samples. A third party company verifies that the abatement company completed the job and the air is clear for re-occupation.  They recognize that there is a bias and potential conflict of interest in collecting your own verification samples.  The mold abatement industry, which has becoming increasing popular, has the same set up.

Knowing in advance that there will be third party verification of work done, or alternatively third party performance of work being recommended, can sometimes change the recommended scope of work.  Sometimes just being aware of the potential for a conflict of interest can prevent the conflict.

Many institutions and organizations recognize that bias or conflicts of interest in their group can have detrimental effects, either financially or in the form of public relations or moral.  More and more institutions and organizations are developing what are called "Recusal Policies".   A recusal policy is a policy that describes the various situations in which an individual has an obligation to remove oneself from participation in a decision because of that individuals prejudice, bias, potential or real conflict of interest. The term "conflict of interest" refers to financial or other personal considerations that may compromise an individual's professional judgment in administration, management, instruction, research, or other professional activities.  Although there are varying degrees of conflicts of interest, it is generally described as a situation in which a person will personally either, benefit from, or be adversely affected by, a decision to be made.

Recommendations from people or professionals that we know have no personal stake or benefits from the decision we will make are the recommendations we value the most.  A recommendation from your Stock Broker is met with skepticism when he will make money from the recommended trade.  A recommendation from your dentist to "replace all your fillings" is suspect when he is the one that is going to replace them and then get paid for it.  Now it's not to say that each of these recommendations is not valid or correct.  It's just that it is our human nature to be skeptical regarding a recommendation coming from the person benefiting from that recommendation. A recommendation from a colleague or some other neutral party is taken as honest advice and is not looked on as potentially biased.

The point of this article is to address the value and significance and the ever increasing roll of third party sampling.  For companies using third party sampling services, the removal of the potential financial bias concentrates the Scientist's energy on the science of the project.  The data collection cost benefit analysis performed free of conflicts of interest, is free from doubt about credibility.

 - Russell Schindler