"Dear NTEU Bargaining Unit Member,
Apparently the [attached] email that was sent as a mass mailer
by the Agency’s Scientific Advisor/Interim Scientific Integrity Official, Dr.
Glenn Paulson, was automatically directed to some of our staff’s Microsoft 365 email
junk boxes. I’m forwarding it to you in the hope that you have a chance
to read the email and attachment, the Scientific Integrity Policy. Please
be aware that NTEU Chapter 280 continues to raise certain concerns with Agency
Management regarding this Policy, as well as Management’s planned Policy
training, and the lack of any comprehensive Policy Implementation plan that
might detail how elements of the Policy might be put into everyday practice.
Please review the attached EPA Scientific Integrity Policy (http://www.epa.gov/osa/pdfs/epa_scientific_integrity_policy_20120115.pdf)
before the scheduled Webinar on the afternoon of Tuesday, August 20
(3:30P-4:30P). Please consider the following issues which have a
particular relevance for those employees in our bargaining unit:
1. Differing
scientific opinions (section A. 3, pg 5)
The Policy has charged the
Scientific Integrity Official and Deputy Scientific Integrity Officials with
the task of developing a “transparent mechanism for Agency employees to express
differing scientific opinions.” If a dispute cannot be resolved in
“internal deliberations” (presumably at the lowest level with one’s supervisor,
or within one’s Office), then the issue is to be addressed in scientific peer
review. This skeleton of a procedure suggests that all science “informing
an Agency policy decision” undergoes scientific peer review and that all at the
Office level are knowledgeable about a particular scientific subject or are
impartial. In some EPA organizations, peer review for scientific product
is not necessarily part of the process for all products, and in some EPA
organizations, scientists and engineers report to lawyers, who may have some
knowledge of science/engineering, but lack the training and education to “get
into the weeds”. For such cases, this would leave the dispute between a
junior employee and his/her immediate supervisor, or other middle and senior
level managers within an Office/Organization. Not only is there a
potential conflict of interest if a desired upper management regulatory outcome
is at odds with the scientific evidence, but the process might be protracted
and might not be documented in any transparent manner. This approach
leaves a junior employee potentially vulnerable to retaliation by middle and
upper managers, and may well result in delays in resolution of the disagreement
related to escalation of the dispute up the chain of command. In effect,
this is a disincentive for the employee to bring forth a differing scientific
opinion.
2. Scientific
Integrity Committee (Section V, pg 10).
The Policy’s authorities are the
Scientific Integrity Official and those who comprise the Scientific Integrity
Committee. The Committee members, termed “Deputy Scientific Integrity
Officials” represent each of the Agency’s Program Offices and Regions.
These individuals are not necessarily scientists or engineers, may have conflicts
of interest with respect to Agency regulatory agenda, and may not necessarily
understand the issues that they are charged with acting on (including a
personal understanding of a defensible and credible scientific product).
Please review the Policy
before the August 20 webinar, and prepare to ask questions and raise your own
concerns. Should you be interested in being engaged in an Agency-wide
forum on the Scientific Integrity Policy, please contact NTEU Steward Dr.
Brenda Seidman (seidman.brenda [at] epa.gov).
Thank you.
Amer Al-Mudallal, President
NTEU Chapter 280
202-566-2789"
