April 3, 2012
Dr. Gary Machlis
Science Advisor to the Director
1849 C Street NW
Washington, DC 20240
Dear Dr. Machlis,
Thank you for the opportunity to comment on the National Park Service's (NPS) draft scientific integrity policy. The policy proposed by NPS upholds the ideals set forth in the directive issued by Secretary Salazar. Although much of the policy is commendable, several areas should be strengthened to ensure the greatest public trust in NPS science.
The American Institute of Biological Sciences (AIBS) is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society. AIBS works to ensure that the public, legislators, funders, and the community of biologists have access to and use information that will guide them in making informed decisions about matters that require biological knowledge. Founded in 1947 as a part of the National Academy of Sciences, AIBS became an independent, member-governed organization in the 1950s. Today, AIBS has nearly 160 member organizations and is headquartered in Reston, Virginia, with a Public Policy Office in Washington, DC.
Applicability to Employees
We strongly support the agency's decision to apply the policy to all NPS employees and appointees who engage in, supervise, manage, or influence scientific activities; communicate scientific information; or use such information to make decisions. We commend NPS for applying the policy to volunteers, contractors, partners, permittees, and others who develop or apply scientific results.
Universal coverage is essential to guaranteeing that the policy is effective. It is vital that decision makers are subject to the policy, otherwise the potential exists for senior NPS officials to misrepresent, alter, or suppress scientific information. The inclusion of communications staff is key to sustaining public trust in NPS and the information the agency communicates to the public and policymakers.
Foundations of Scientific Integrity
In its December 2010 memorandum on scientific integrity, the Office of Science and Technology Policy (OSTP) outlined several foundational principles that should be included in each agency's respective scientific integrity policy. As currently written, neither the NPS policy nor Interior's Departmental Manual explicitly states the Department's commitment to several of these principles. NPS should rectify this by incorporating the following principles into its final scientific integrity policy.
Code of Scientific and Scholarly Conduct
The draft policy outlines a code of ethics for employees, scientists, and importantly those who supervise and manage scientific activities. The proposed code of conduct would benefit from two additions:
Scientific Societies and Professional Development
We strongly support the policy's encouragement of NPS scientists to serve in the leadership of professional and scientific societies. The participation of government scientists in scientific societies contributes to their professional development and to that of the scientific community.
Additionally, we urge NPS to encourage its employees to publish research findings in peer-reviewed scholarly journals, to present research findings at professional meetings, and to serve as editors of scholarly journals. The December 2010 memorandum on scientific integrity from OSTP explicitly states that agencies should encourage these activities, as well as allow government scientists to receive honors and awards for their research and discoveries. The draft NPS policy does not currently address these matters, nor does Interior's Departmental Manual.
Training on Scientific Integrity
We encourage NPS to include in its final policy a commitment to provide regular integrity and ethics training to its employees, appointees, and contractors. This should include training to new and existing staff. Additionally, NPS should provide information to ensure that employees and contractors are fully aware of their rights regarding dissemination of their research, participation in professional scientific societies, and their responsibility to report waste, fraud, abuse, and scientific misconduct.
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.