September 6, 2011
Dr. Subra Suresh
National Science Foundation
4201 Wilson Boulevard
Arlington, VA 22230
Re: Draft Scientific Integrity Policy
Dear Dr. Suresh,
Thank you for the opportunity to comment on the National Science Foundation's (NSF) draft scientific integrity policy.
The American Institute of Biological Sciences (AIBS) is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society. Founded in 1947 as a part of the National Academy of Sciences, AIBS became an independent, member-governed organization in the 1950s. AIBS is sustained by a robust membership of individual biologists and nearly 200 professional societies and scientific organizations with a combined individual membership exceeding 250,000.
As is noted in the draft policy, NSF already has in place a number of policies to ensure the integrity of the merit review process and other agency actions. While it is commendable that NSF has been a leader in implementing a conflict of interest policy for investigators, this and other past actions are not sufficient to implement the guidance issued by the Office of Science and Technology Policy. NSF should make several changes to the policy in order to fully ensure the integrity of science.
Applicability to Employees
We strongly encourage NSF to state that the policy applies to all NSF employees, appointees, and contractors who engage in, supervise, or manage scientific activities; analyze or communicate scientific information; or use such information to make decisions. Universal coverage is essential to ensuring that the policy is effective. It is vital that decision-makers are subject to the policy, otherwise the potential exists for decision-makers to misrepresent, alter, or suppress scientific information, as has happened at other science agencies in recent years. The inclusion of communications staff is key to sustaining the public trust in NSF and the information the agency communicates to the public.
Code of Scientific Conduct
Several federal agencies have elected to include in their draft scientific integrity policies a code of conduct to guide the behavior of agency scientists. The National Oceanic and Atmospheric Administration (NOAA) went one step farther and devised a code of ethics for science supervisors and managers.
We recognize that NSF is a very different type of science agency, since it does not employ large numbers of government scientists to conduct intramural research. NSF, however, does employ statisticians, social scientists, and researchers in its National Center for Science and Engineering Statistics (NCSES). According to the NSF website: "As one of 13 federal statistical agencies, NCSES designs, supports, and directs periodic national surveys and performs a variety of other data collections and research." In addition, many staff throughout the agency analyze and communicate scientific results.
It is therefore necessary for NSF to develop a code of scientific conduct to guide employee actions. The codes of conduct included in NOAA's draft scientific integrity policy (sections 6 and 7) could serve as a good model for NSF.
Principles of Scientific IntegrityAs currently written, the draft policy highlights many actions that NSF has already completed to address scientific integrity, such as an investigator conflict of interest policy. While these actions are an important part of agency's ability to ensure the integrity of science, they are not comprehensive.
NSF's policy would be much stronger if it included a set of guiding principles on scientific integrity. Other science agencies, such as the Department of the Interior and NOAA included principles of scientific integrity in their draft policies. Examples of principles that are not currently addressed in NSF's policy include:
We encourage NSF to include these and other principles in their final policy.
The draft policy states that NSF staff can "participate in any research or educational institution, scientific society, professional association or editorial board, provided written permission is obtained from the scientist's or engineer's supervisor or ethics counselor." This standard is significantly more restrictive than other science agencies. For instance, NOAA encourages employees to join scientific and professional societies and does not require employees to seek permission beforehand. We strongly encourage NSF to revise their policy to allow employees to freely join scientific and professional societies.
We also urge you to clarify the policy to address the rule recently issued by the Office of Government Ethics that allows federal employees to serve on the board of directors and as officers of non-profit organizations, including scientific societies.
Thank you for your thoughtful consideration of these comments. If AIBS may be of further assistance to you on this or any other matter, please contact Dr. Robert Gropp, AIBS Director of Public Policy at 202-628-1500.
Richard O'Grady, Ph.D.