December 13, 2011

Dr. Jane Lubchenco
Under Secretary for Oceans and Atmosphere
Administrator, National Oceanic and Atmospheric Administration
1401 Constitution Avenue, NW
Room 5128
Washington, DC 20230

Re: Scientific Integrity Policy

Dear Dr. Lubchenco:

Thank you for making scientific integrity within the National Oceanic and Atmospheric Administration (NOAA) a priority. The agency's scientific integrity policy is a comprehensive document that upholds the ideals espoused by President Obama to restore science to its rightful place. Indeed, NOAA's policy might be used as a model by other federal departments and agencies.

I commend you and your staff for the open process used to develop the policy. Public input clearly helped to strengthen and clarify several aspects of the policy and the accompanying procedural handbook. The scientific integrity policy incorporates a number of important revisions regarding applicability to employees and freedom of speech for agency scientists.

Although we at AIBS appreciate NOAA's position that the procedural handbook is a living document that is "expected to evolve over time," a few sections deserve special attention and we recommend more immediate action. NOAA is encouraged to continue to refine the decision making process used by a review panel when investigating allegations of scientific misconduct. The United States Geological Survey's scientific integrity policy is a good model in this regard. Additionally, NOAA should reevaluate its timeframe for the collection of evidence when misconduct is alleged. We recognize and appreciate NOAA's response to public comments on this topic and agree that an artificially short timeframe for collecting information and data could hinder an investigation. Nonetheless, the agency should articulate a policy and procedure for moving quickly to begin securing information and data that will be used to evaluate a claim. A procedure that outlines the steps to be taken to secure information in a timely fashion should be included in the handbook.

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 approximately 160 professional societies and scientific organizations with a combined individual membership exceeding 250,000.

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.


James P. Collins, Ph.D.

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