September 6, 2011
Ms. Lisa Jackson
Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Re: Draft Scientific Integrity Policy
Dear Administrator Jackson,
Thank you for the opportunity to comment on the Environmental Protection Agency's (EPA) draft scientific integrity policy. The policy will help ensure public trust in EPA science. The draft policy, however, could be significantly strengthened with several key additions.
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.
Applicability to Employees
The agency's decision to apply the policy to all EPA employees and appointees who engage in, supervise, or manage scientific activities; analyze or communicate scientific information; or use such information to make decisions is commendable. 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. The inclusion of communications staff is key to sustaining the public trust in EPA and the information the agency communicates to the public. For these reasons, we urge you to revise the policy to include all contractors employed by EPA.Principles of Scientific Integrity
The draft policy outlines a number of important principles that are integral to fostering scientific integrity. The addition of several other principles would significantly strengthen the policy.
Additionally, the draft policy appears to be inconsistent as to which employees are expected to uphold the principles of scientific integrity. Appendix A states that "EPA employees, whatever their grade, job or duties," must uphold the principles. Section IV, however, states that "EPA scientists and engineers, regardless of their grade, position, or duties" should abide by the principles of scientific integrity. Section IV of the draft policy should be revised to state that all EPA employees are subject to the principles. Otherwise, it appears only EPA scientists and engineers should "ensure that their work is of the highest integrity, free from political influence." It should not be the responsibility of scientists alone to ensure the absence of political influence in EPA science. Rather this should be an endeavor that is the responsibility of all EPA employees, appointees, and contractors.
Code of Scientific Conduct
Several federal agencies have included in departmental 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. EPA has already incorporated some, but not all, aspects of such ethical codes into its draft policy. EPA is strongly encouraged to develop codes of scientific conduct to guide the behavior of scientists and managers. The codes of conduct included in NOAA's draft scientific integrity policy (sections 6 and 7) could serve as a good model for EPA.
Communications with the Media and Public
Although the basic tenants underlying Section IV.B are admirable, the draft policy lacks several specific details that are needed to ensure that the scientific integrity policy is properly implemented.
First, this section of the policy should include managers and supervisors of scientists. The policy should state that managers and supervisors must never suppress, alter, or otherwise impede the timely release of scientific or technological findings or conclusions. Managers and supervisors will not intimidate or coerce employees to alter or censor scientific findings, nor shall they implement institutional barriers to cooperation and the timely communication of scientific findings or technology.
Furthermore, policy officials should be expected to release to the public the scientific or technological findings or conclusions considered or relied on in policy decisions.
In order to fully comply with the Office of Science and Technology Policy memorandum dated December 17, 2010, EPA should "communicate scientific and technological findings by including, when necessary and appropriate, a clear explication of underlying assumptions; accurate contextualization of uncertainties; and a description of the probabilities associated with both optimistic and pessimistic projections, including best-case and worse case scenarios." Additionally, EPA should publically release "data and models underlying regulatory proposals and policy decisions."
Lastly, EPA should develop an agency-wide framework for deciding how written and audiovisual materials will be approved for public dissemination. This guidance should include time limits for review and approval, and procedures for redress if time limits are not met.
Scientific Societies and Professional Development
EPA is strongly commended for supporting the participation of agency scientists in the leadership of professional and scientific societies, the publication of results in peer-reviewed journals, the presentation of research at scientific meetings, and active participation in professional societies. As is noted in the draft policy, "scientific leadership is a key component of advancing the mission of EPA." The engagement of federal scientists in scientific societies is key for the professional development of these researchers and for the advancement of science. To this end, we encourage EPA to state in its final policy that its scientists and engineers are able to accrue the professional benefits of honors and awards for their research and discoveries.
Scientific Integrity Committee
The creation of a committee on scientific integrity and the designation of a Scientific Integrity Official are commendable. The leadership of these individuals should help to ensure that the scientific integrity policy is well implemented across the entire agency. It is particularly valuable that the committee will track and report annually on cases of misconduct. Indeed, this concept was recommended by the Inspector General for the Department of the Interior for the bureaus under its jurisdiction. The development of a training program related to scientific integrity for agency staff is also notable.
Thank you for the opportunity to comment on the draft scientific integrity policy. 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.