Memo to EPA Employees: Scientific Integrity
DATE: May 9, 2009
SUBJECT: Scientific Integrity: Our Compass for Environmental Protection
FROM: Lisa P. Jackson, Administrator
TO: All EPA Employees
On March 9, President Obama issued a Memorandum on Scientific Integrity underscoring that the “public must be able to trust the science and scientific process informing public policy decisions.” The public health and environmental laws that Congress has enacted depend on rigorous adherence to the best available science. That is why, when I became Administrator, I pledged to uphold values of scientific integrity every day.
Science must be the compass guiding our environmental protection decisions. We cannot make the best decisions unless we have confidence in the integrity of the science on which we rely. Therefore, it is my promise that scientific integrity will be the backbone of my leadership of the Agency.
The President’s Memorandum provides important guideposts for how EPA should conduct and use science. Most notable is that “political officials should not suppress or alter scientific or technological findings and conclusions.” While the laws that EPA implements leave room for policy judgments, the scientific findings on which these judgments are based should be arrived at independently using well-established scientific methods, including peer review, to assure rigor, accuracy, and impartiality. This means that policymakers must respect the expertise and independence of the Agency’s career scientists and independent advisors while insisting that the Agency’s scientific processes meet the highest standards of rigor, quality, and integrity.
The President’s Memorandum stresses that “scientific information … developed and used by the Federal government should … ordinarily be made available to the public” and that, where permitted by law, “there should be transparency in the preparation, identification and use of scientific and technological information in policymaking.” Consistent with this principle and my commitment to transparency, I believe that the methodologies and guidelines that EPA uses for scientific analyses should be shared fully with the public. Our regulatory decisions should include a full explanation of the science issues addressed by the Agency, the data relevant to those issues, and the interpretations and judgments underlying the Agency’s scientific findings and conclusions.
Like other aspects of our programs, environmental science is complex and multi-faceted. Able scientists may not always agree on what methodologies should be employed or how studies should be interpreted. I am committed to fostering a culture of robust scientific debate and discussion within the Agency, recognizing that in the end senior scientists must take responsibility for resolving differences of opinions using established science policies and their best professional judgment. I intend to work with our science leadership, unions, and career staff to make sure that we respect and encourage free and honest discussion among our scientists while bringing to closure issues that we must resolve to support decision making.
EPA already has a strong foundation of policies and procedures that support the President’s goals. EPA’s Principles of Scientific Integrity, developed in 1999 and reaffirmed in 2002, foster honesty and credibility in the science conducted by and used by the Agency. The Quality Program further ensures that the data relied upon for decision making is of known and documented quality and is based on sound scientific principles. EPA’s Peer Review Handbook is recognized as a model for good peer review practices. The Agency’s regulatory development process provides for Analytic Blueprints that formalize scientific input. EPA also has strict rules in place to address scientific misconduct and whistleblower protections not only for the scientific process, but for all of EPA’s activities.
However, we should build on this foundation and look for opportunities to strengthen the policies and procedures that ensure scientific integrity within the Agency. I have asked EPA’s Science Policy Council, which provides leadership in cross-Agency science and science policy issues, to take the lead on this effort. The SPC at my request is inventorying all our guidelines and policies that relate to scientific integrity to look for gaps and possible areas for improvement. One SPC focus, for example, will be updating and reaffirming EPA’s Peer Review Handbook and recommending how we can improve implementation of our peer review policies across our programs and regions. I also have asked the SPC to work the National Partnership Council to reaffirm the Agency’s Principles of Scientific Integrity and update the Principles of Scientific Integrity online training.
The President’s Memorandum on Scientific Integrity assigns the Director of the White House Office of Science and Technology Policy the responsibility to make recommendations within 120 days to achieve the “highest level of integrity in the executive branch’s involvement with scientific and technological processes.” EPA’s active involvement with OSTP in this Presidential directive will strengthen our ability to produce top-quality science that meets the highest standards of integrity. Accordingly, I have asked our Acting Science Advisor, Kevin Teichman, in consultation with the SPC, to work closely with OSTP. After OSTP issues its recommendations, I will work closely with the SPC to make sure we are fully applying them at EPA.
The Presidential Memorandum on Scientific Integrity provides us with a unique opportunity to once again demonstrate our deep commitment to scientific integrity in the pursuit of our vital mission of protecting human health and the environment. Let us seize this opportunity by always minding the direction of our compass.
PRESIDENTIAL MEMO FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES (9 March 2009)
SUBJECT: Scientific Integrity
Science and the scientific process must inform and guide decisions of my Administration on a wide range of issues, including improvement of public health, protection of the environment, increased efficiency in the use of energy and other resources, mitigation of the threat of climate change, and protection of national security.
The public must be able to trust the science and scientific process informing public policy decisions. Political officials should not suppress or alter scientific or technological findings and conclusions. If scientific and technological information is developed and used by the Federal Government, it should ordinarily be made available to the public. To the extent permitted by law, there should be transparency in the preparation, identification, and use of scientific and technological information in policymaking. The selection of scientists and technology professionals for positions in the executive branch should be based on their scientific and technological knowledge, credentials, experience, and integrity.
By this memorandum, I assign to the Director of the Office of Science and Technology Policy (Director) the responsibility for ensuring the highest level of integrity in all aspects of the executive branch’s involvement with scientific and technological processes. The Director shall confer, as appropriate, with the heads of executive departments and agencies, including the Office of Management and Budget and offices and agencies within the Executive Office of the President (collectively, the “agencies”), and recommend a plan to achieve that goal throughout the executive branch.
Specifically, I direct the following:
1. Within 120 days from the date of this memorandum, the Director shall develop recommendations for Presidential action designed to guarantee scientific integrity throughout the executive branch, based on the following principles:
(a) The selection and retention of candidates for science and technology positions in the executive branch should be based on the candidate’s knowledge, credentials, experience, and integrity;
(b) Each agency should have appropriate rules and procedures to ensure the integrity of the scientific process within the agency;
(c) When scientific or technological information is considered in policy decisions, the information should be subject to well-established scientific processes, including peer review where appropriate, and each agency should appropriately and accurately reflect that information in complying with and applying relevant statutory standards;
(d) Except for information that is properly restricted from disclosure under procedures established in accordance with statute, regulation, Executive Order, or Presidential Memorandum, each agency should make available to the public the scientific or technological findings or conclusions considered or relied on in policy decisions;
(e) Each agency should have in place procedures to identify and address instances in which the scientific process or the integrity of scientific and technological information may be compromised; and
(f) Each agency should adopt such additional procedures, including any appropriate whistleblower protections, as are necessary to ensure the integrity of scientific and technological information and processes on which the agency relies in its decisionmaking or otherwise uses or prepares.
2. Each agency shall make available any and all information deemed by the Director to be necessary to inform the Director in making recommendations to the President as requested by this memorandum. Each agency shall coordinate with the Director in the development of any interim procedures deemed necessary to ensure the integrity of scientific decisionmaking pending the Director’s recommendations called for by this memorandum.
3. (a) Executive departments and agencies shall carry out the provisions of this memorandum to the extent permitted by law and consistent with their statutory and regulatory authorities and their enforcement mechanisms.
(b) Nothing in this memorandum shall be construed to impair or otherwise affect:
(i) authority granted by law to an executive department, agency, or the head thereof; or
(ii) functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals.
(c) This memorandum is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity, by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
4. The Director is hereby authorized and directed to publish this memorandum in the Federal Register.