In 2017, a woman named Nancy Beck left her position as Senior Director of Regulatory Science Policy at the American Chemistry Council — the chemical industry's most powerful lobbying group — and walked into the Environmental Protection Agency as Deputy Assistant Administrator of the Office of Chemical Safety and Pollution Prevention. The office she now led was the same one her former employer spent millions lobbying against.
Within months, Beck was rewriting rules that governed the very chemicals her industry colleagues manufactured. She weakened the EPA's proposed Significant New Use Rule for long-chain PFAS chemicals like PFOA and PFOS — the "forever chemicals" now found in the blood of virtually every American. Career EPA scientists objected. The rules were softened anyway.
This is not an anomaly. This is the system working exactly as designed.
What the Revolving Door Actually Looks Like
The term "revolving door" describes the movement of individuals between government regulatory positions and jobs in the industries those agencies oversee. In environmental regulation, this movement is so common it has become structural. It is not a bug in American governance — it is a feature that has been refined over decades.
Consider the EPA's Office of Pesticide Programs. Since 1974, according to research by Beyond Pesticides, every director of that office who continued working after leaving the agency took a position with the pesticide companies they had previously regulated. Some joined as consultants. Others landed on corporate boards. Several took university positions funded by agrochemical giants like Monsanto, Bayer, and Syngenta — positions that carry academic prestige while serving industry interests.
Steven Jellineck, a former Assistant Administrator for Toxic Substances, founded a consulting firm that represented Monsanto, Dow, FMC, and the Chemical Manufacturers Association. Linda Fisher, another Assistant Administrator, moved to Monsanto and later DuPont. Stephen Johnson, after serving as EPA Administrator, joined the board of Scotts Miracle-Gro, a company that markets glyphosate-based herbicides. The pattern is not subtle.
The door swings both ways. Industry veterans arrive in government with deep expertise — and deep loyalties. Douglas Troutman, confirmed as Assistant Administrator of the EPA's Office of Chemical Safety and Pollution Prevention, previously served as interim CEO and lobbyist at the American Cleaning Institute, an organization that routinely pushes back against chemical regulation. He now oversees the regulations his former organization fought.
Why This Matters for Environmental Protection
The revolving door does not merely create the appearance of conflict of interest. It produces measurable policy outcomes that favor industry over public health.
When a regulator knows — consciously or not — that their next career move depends on maintaining good relationships with the companies they oversee, enforcement softens. Permit conditions become more flexible. Compliance deadlines stretch. Penalties shrink. The result is not dramatic corruption. It is a slow, steady erosion of the regulatory standards that protect communities from toxic exposure.
Nancy Beck's trajectory illustrates the mechanism precisely. At the American Chemistry Council, she worked to relax federal guidelines on harmful chemicals. At the EPA, she pursued policies that achieved the same goal — but now with the force of federal authority behind them. When career scientists pushed back on weakened PFAS rules, political leadership overruled them. Beck later moved to the White House National Economic Council, then returned to the EPA in 2025 as Principal Deputy Assistant Administrator in the same chemical safety office. Each rotation through the door deepened industry's influence on the regulatory apparatus.
A 2020 investigation by Senator Tom Carper of the Senate Environment and Public Works Committee found leaked documents showing that Beck, while at the White House, actively worked to weaken EPA action on PFAS. The chemicals she helped shield from regulation are now the subject of a national drinking water crisis, with the EPA setting a maximum contaminant level of just four parts per trillion — an acknowledgment of how dangerous these substances are at even trace concentrations.
The Legal Framework That Fails to Prevent It
Federal law does impose restrictions on post-government employment. Under 18 U.S.C. § 207, former federal employees face a lifetime ban on representing third parties in specific matters they personally worked on, a two-year restriction on matters under their official responsibility, and a one-year cooling-off period during which senior employees cannot lobby their former agency on any matter.
On paper, these rules sound robust. In practice, they are full of gaps.
The lifetime ban applies only to "particular matters involving specific parties" — a narrow category that excludes general rulemaking, policy development, and the broad regulatory frameworks that shape entire industries. A former EPA official cannot lobby on the specific permit they approved, but they can advise a company on how to influence the entire permitting process. The one-year cooling-off period for senior employees prohibits direct communication with the former agency, but it does not prevent the former official from advising clients behind the scenes, crafting lobbying strategies, or leveraging their institutional knowledge for private gain.
Moreover, enforcement is thin. The Office of Government Ethics provides guidance and training, but it has limited investigative authority. The Department of Justice can prosecute violations of Section 207, but such cases are exceedingly rare. The practical reality is that compliance is largely self-policed — a system that relies on the honor of the very people it is designed to constrain.
At the state level, protections are even weaker. Many states have no meaningful cooling-off periods for environmental regulators. A state environmental agency director can resign on Friday and begin consulting for a regulated landfill operator on Monday, carrying with them intimate knowledge of pending enforcement actions, internal risk assessments, and the regulatory vulnerabilities of competing companies.
The Waste Industry Is Not Immune
While much of the public attention on the revolving door focuses on the chemical and pesticide sectors, the solid waste industry operates within the same dynamics. Landfill permitting, hazardous waste classification, Superfund cleanup decisions, and methane emissions regulation all involve complex technical and legal frameworks where industry expertise is valuable — and where former regulators command premium consulting fees.
The National Waste & Recycling Association, the industry's primary trade group, engages continuously with the EPA on the National Recycling Strategy, landfill methane emissions standards, and PFAS regulations. The relationships between agency staff and industry representatives are, in many cases, collegial and long-standing. This is not inherently corrupt — but it creates conditions where the boundary between regulator and regulated becomes permeable.
When a state environmental inspector who spent years reviewing a company's compliance record leaves to join that company's environmental compliance team, the institutional knowledge they carry is not neutral. They know which violations the agency prioritizes. They know which inspectors are thorough and which are stretched thin. They know the internal thresholds that trigger enforcement action — and, critically, those that do not.
What Meaningful Reform Would Require
Addressing the revolving door requires more than ethics pledges and cooling-off periods. It requires structural changes to how we compensate, retain, and protect the people who do the work of environmental regulation.
First, compensation matters. Federal and state environmental regulators are consistently underpaid relative to their private-sector counterparts. A GS-13 environmental scientist at the EPA earns a fraction of what the same expertise commands at an environmental consulting firm or a regulated company. As long as the financial incentive to leave government is overwhelming, the revolving door will continue to spin.
Second, cooling-off periods must be extended and broadened. A one-year ban on direct lobbying is insufficient when the real influence happens through strategic advising, industry conferences, and informal networks. Several reform proposals have called for extending the cooling-off period to five years for senior officials and expanding its scope to include indirect lobbying and consulting on regulatory matters.
Third, transparency must improve. Public disclosure of post-government employment by former regulators should be mandatory and easily accessible. Citizens should be able to see, with minimal effort, where the people who wrote their environmental rules ended up — and who is paying them now.
Fourth, we must invest in the career civil service. The EPA's workforce has been shrinking for decades. In the 1990s, the agency employed roughly 18,000 people. Today that number is significantly lower, even as the scope and complexity of environmental threats have grown enormously. When agencies are understaffed, institutional knowledge concentrates in fewer people — making each departure to industry more damaging.
Why We Are Watching
At the EPR Foundation, we believe that effective environmental regulation depends on public trust — and public trust depends on the integrity of the people doing the regulating. The revolving door undermines that integrity, not because every person who moves between government and industry is corrupt, but because the system creates incentives that consistently favor industry interests over public health.
We do not believe the solution is to demonize individuals or to pretend that industry expertise has no place in government. People who understand how chemicals are manufactured, how waste is managed, and how environmental systems function are exactly the people we need in regulatory roles. The problem is not expertise. The problem is the absence of guardrails that prevent expertise from being captured.
The revolving door is not a conspiracy. It is a structural failure — one that can be repaired with political will, adequate funding, and a citizenry that demands better. The first step is seeing it clearly.
When the people writing the rules and the people profiting from the rules are the same people at different points in their careers, the rules will eventually serve only one master. That is not governance. That is regulatory capture — and it is happening in plain sight.