Scientific Integrity and EPA's Scientific Integrity Policy - Part One

“Scientific Integrity” and EPA’s Scientific Integrity Policy

EPA will soon require an unspecified number of staff members to take an on-line training course intended to familiarize them with its Scientific Integrity Policy.  NTEU280, in an effort to educate its bargaining unit on the Policy’s laudable, as well as worrisome, elements, is initiating this blog series.  

Today’s blog entry begins with the most basic of questions – what is “scientific integrity”?  

A succinct answer to this question cannot be found in the Policy, the Principles of Scientific Integrity [1] upon which it was developed, in President Obama’s March 9, 2009 scientific integrity “kick-off” memo [2], or in the December 17, 2010 Office of Science and Technology Policy [3] memo on the subject of President Obama’s memo, although each document describes elements relating to what might go into a definition of “scientific integrity."

A good working definition for our purposes of “science” might be “knowledge about or study of the natural world based on facts learned through experiments and observation" [4].  

So what about “integrity”?  Here are a couple definitions [5]: "integrity" may be defined as “the quality of being honest and fair”; “the state of being complete or whole”

Combining the two definitions for the two words, we might have the following working definition for “scientific integrity":

Scientific Integrity:  knowledge or study of the natural world based on facts learned through experiments and observation, and which are arrived at, and represented, in an honest and fair manner.

Questions for our readers

• What do you think of the proposed definition for “scientific integrity”?  Any suggestions of your own? 

• Do you think that the Venn diagram below captures all of the elements and interrelationships of “scientific integrity”?  If it falls short, what do you think is amiss?

• How does personal character come into play in scientific integrity?  Are there other qualities or devices that might be critical to the integrity of an organization’s science?  What do you think those are?  

 Please send your comments to NTEU280 (nteu280blog@gmail.com) and and note if you would like them posted in our next Scientific Integrity blog posting.  All comments will be posted without identifying information. 

[Carleton University, Department of Psychology, Ottawa, ON, Canada.  http://www2.carleton.ca/psychology/ethics/ - Accessed 09.22.2013]] 

Stay tuned for more!

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[1] USEPA.  National Labor Partnership.  EPA’s Principles of Scientific Integrity.  (Release/publication date not noted)

[2] Obama, Barack.  White House. Press Release.  Memorandum for the Heads of Executive Departments and Agencies.  Subject: Scientific Integrity.  March 9, 2009. 

[3] Holdren, John P.  Office of Science and Technology.  Memorandum for the Heads of Executive Departments and Agencies.  Subject:  Scientific Integrity.  December 17, 2010.

[4] http://www.merriam-webster.com/dictionary/science [Accessed 09.22.2013]

[5] http://www.merriam-webster.com/dictionary/integrity [Accessed 09.22.2013]

Scientific Integrity Policy - Message from Chapter President to Bargaining Unit Employees

"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"