June 29, 2004
Deborah D. Stine, Ph.D.
Committee on Science, Engineering, and Public Policy
The National Academies
500 5th Street, NW
Washington, DC 20001
Dear Dr. Stine:
The American Institute of Biological Sciences (AIBS) submits the following in response to the National Academies of Science (NAS) request for comments to inform the work and subsequent report of the Committee on Ensuring the Best Science and Technology Presidential and Advisory Committee Appointments. The scope of the request for comment suggests that the Committee is planning a more encompassing report than the one released in 2000, which focused on cabinet and senior sub-cabinet level presidential appointments. The recommendations of that report still seem appropriate today. Thus, our comments address only the question of "what principles should guide the selection of scientists, engineers, and health professionals to serve on federal advisory committees associated with science-based policy or to review research proposals?"
Several guiding principles should be considered in selecting advisory committee and research review committee participants, and managing the work of these panels.
Candidates for advisory committees and research review panels should have a demonstrated record of scientific achievement relevant to the matters to be considered. It must be recognized, however, that for some matters the universe of highly qualified scientific experts may be small and many of these individuals may have previous or existing relationships with the agency the committee is charged with advising. Rather than disqualifying these individuals for potential conflict of interest, the candidate's scientific expertise and ability to provide impartial evaluations should be considered.
Processes for selecting advisory committee and research review panelists, and managing the activities of the panel must be flexible. For example, rigid guidelines dictating the number of experts to be seated on advisory committees could hinder a committee's ability to provide scientific evaluations.
Efforts should be made to ensure that advisory committees and review panels include an appropriate representation of scientific expertise relevant to the matters to be considered. Vesting the responsibility for selecting scientific experts with appropriate scientific organizations and/or agency science managers could help ensure the selection of appropriately qualified individuals while simultaneously increasing the independence of the committee by reducing the influence of politically appointed or elected officials.
The National Academies in collaboration with scientific societies should develop guidance on disciplinary differences in scientific culture, and methods for helping agency administrators and committee members understand and work through these differences.
An ever-present challenge facing the science community and federal agencies that administer science programs or promulgate regulations based on science is an inadequate public understanding of the nature of science. While federal agencies and scientific organizations support efforts to increase the public understanding of science, these initiatives should be strengthened. An improved public understanding of science would enable the public to make more informed decisions about the independence of scientific advisory committees.
In April 2004, the United States General Accounting Office (GAO) released "Federal Advisory Committees: Additional Guidance Could Help Agencies Better Ensure Independence and Balance" (GAO-04-328). Importantly, the GAO report primarily discusses methods for increasing public confidence in the balance of federal advisory committees. A concern within the scientific community and a common criticism raised by special interest groups spanning the political spectrum is that politically appointed or motivated officials ignore or selectively utilize the recommendations of scientific advisory boards. Thus, the Committee should consider recommending methods and mechanisms for making advisory committee findings and recommendations available to the public prior to the advisory committee's findings being "signed-off" by federal agency personnel, including the Office of Management and Budget. Obviously, exceptions would have to be made for legitimate national security, individual privacy, and proprietary interests. For certain politically charged issues, such as climate change or stem cell research, making committee findings available to the public at the same time they are submitted to a federal agency or the White House could increase public and scientific community confidence in the independence of the committee.
Thank you for the opportunity to comment on this important matter. If you require further information about AIBS' suggestions, please contact Dr. Robert Gropp at 202-628-1500 x 250.
Richard O'Grady, Ph.D.