EPA Releases New Scientific Integrity Policy
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The Environmental Protection Agency (EPA) released an updated version of its scientific integrity policy today.
A draft was released for public comment early last year. The revised policy is part of new processes implemented by the Biden administration on scientific integrity.
The scientific integrity policy comes on the cusp of President-elect Trump’s inauguration – a president whose prior administration was marred by the most attacks on federal science in U.S. history. Many of these attacks on science occurred at the EPA – an agency whose work is often politicized. Strong scientific integrity at the EPA is always needed, given that attacks on science happen under every administration – Republicans and Democrats. However, the Trump administration will undoubtedly bring unprecedented challenges to federal science if history is prologue.
In fact, Lee Zeldin, Trump’s nominee to lead the EPA, is set to have a confirmation hearing today. Before the Senate votes, he should be asked to commit to a strong scientific integrity policy in the hearing and subsequent meetings.
The EPA has consistently been a leader among federal agencies on scientific integrity. Its policy and processes have been rated highly, and often, the agency implements new ideas to strengthen scientific integrity before other agencies. The updated policy is no exception—it is excellent. Below, we’ve highlighted some areas where the policy ensures strong scientific integrity that federal scientists may want to take note of.
Focusing on the Culture of Scientific Integrity
The EPA’s new scientific integrity policy begins its provisions by discussing promoting a culture of scientific integrity. To some, this may seem odd. Why not jump into the details of implementation or other processes? But to me, this is the most important part of this policy—establishing a culture.
The EPA reaffirms and will continue to promote a culture of scientific integrity across the agency by enhancing transparency and protecting agency science and employees who conduct, manage, use, and communicate science. This means (1) creating an empowering environment conducive to innovation and progress, (2) safeguarding agency science and scientists, and (3) preserving the integrity of the scientific process and the communication of science.
Establishing a culture of scientific integrity is so critically important because culture can do what a policy cannot – survive. Unfortunately, an administration can easily undo agency policies with a pen stroke. It is not hypothetical that scientific integrity policies may be eliminated – in fact, as SciLight has written before, some folks are advocating that the Trump administration do just that. And it also seems that Congress is planning to target scientific integrity and cast the issue as partisan (it’s not).
Even if the policy is not there, the culture of scientific integrity remains. This means that the EPA, its scientists, and its staff value scientific integrity and will continue to uphold it. As the policy states multiple times, “Scientific integrity is everyone’s responsibility.”
Preventing the Politicization of Science Communication
Federal agencies, including the EPA, do scientific work critical to our environment and the public's health. Therefore, the public must have access to this vital information, especially in times of crisis (e.g., natural disasters). However, federal agency scientific information can sometimes be suppressed or delayed for political reasons. The EPA’s scientific integrity policy protects against politicizing the free flow of scientific information to the public.
It is the policy of EPA to: Not suppress, unreasonably delay, or alter scientific findings and products for non-scientific reasons or due to political interference or inappropriate influence. This includes scientific findings and products generated by contractors, grantees, or other agency partners who assist with developing or applying the results of scientific activities.
Under many administrations across party lines, we have seen scientific reports or products unnecessarily delayed. This is sometimes due to scientific reasons (e.g., more data are needed). However, sometimes, there is no scientific reason, and one might question why an administration is not releasing scientific information. The EPA’s policy provides explicit provisions on the clearance procedures for scientific information and should be utilized when the free flow of scientific information is being politicized.
To ensure the free flow of scientific information, the EPA’s updated scientific integrity policy also allows scientists to “objectively communicate their cleared scientific activities without political interference or inappropriate influence.” The policy also specifies that it will “Support agency employees’ participation in communications with the media regarding their scientific activities and areas of scientific expertise in their official capacities where appropriate.” The policy allows scientists to speak freely about their work and expertise, which could be crucial in an emergency.
This point is further illustrated in a new provision in the policy that calls attention to the agency’s 2016 elevation policy. The elevation policy was borne from disasters that should’ve been prioritized or elevated to senior leadership – think about the lead crisis in Flint, Michigan. The EPA’s new scientific integrity policy states that it will “Inform EPA employees and increase awareness of the agency’s Elevation Policy and associated internal web tool for providing agency senior management with notice of a perceived unaddressed significant risk to public health or the environment that is within the scope of the EPA’s authorities.”
The public must have the best available scientific information to help limit health risks or harm. The EPA’s policy ensures that scientists can deliver such information to the public without political interference.
Differing Scientific Opinions
The EPA has stood out as a leader in scientific integrity and may have been the first agency to introduce, implement, and have staff utilize a differing scientific opinion (DSO). A DSO is described in EPA’s new policy as an opinion that “contrasts with a prevailing staff opinion included in a scientific product under development that concerns scientific data, environmental information, analysis, interpretations, or conclusions, rather than policy options or decisions.” The DSO is reserved for an EPA scientist that is “substantively engaged in the science,” which makes sense given they understand the science informing a particular decision better than anyone else.
Dr. Thomas Sinks issued a DSO before he left the EPA regarding the agency’s final “Strengthening Transparency in Regulatory Science” rule. The rule, vacated in court, would have limited the public health science EPA relies on to inform public health regulations, like reducing air pollution. Dr. Sinks’ DSO clarified how the rule would compromise the EPA’s mission to protect human health and the environment, and it was helpful information to outside parties regarding how internal processes may have not aligned with the best available science and information.
And there’s more!
I could make this post very long discussing all the new and good provisions in EPA’s new scientific integrity policy. It has a whole new section on accountability, for example. But, in the interest of space and your time, I will encourage you to read it yourself. And if you are a current EPA scientist, I implore you to read it and familiarize yourself with it. It will be a helpful resource in the years to come, as we have pointed out in our toolkit for federal scientists, which we released last year.
President Trump will be inaugurated next Monday, on MLK day no less (what an irony given his many attacks on DEI). When Trump took office last time, the attacks on science began on Day One. And I remember that the EPA was explicitly targeted. EPA scientists were censored immediately, climate change information was deleted from agency webpages, and the agency’s grant process was changed to undermine crucial scientific work. Scientific integrity is more important than ever, so seeing a strong policy and culture at the EPA is good.
Thank you to everyone who worked on this policy – it is important work that could literally save lives.
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