Progress on Scientific Integrity in the Past Three Years
I write extensively about scientific integrity on SciLight. I often mention that actions taken under the Biden administration have strengthened it. However, I realize I have yet to explain how federal scientific integrity was strengthened. Such details are important to many of my blogs, so let’s revisit what has happened during the past three years.
The pressing need for more robust scientific integrity policies
As the Biden administration assumed office, it did so in the wake of the Trump administration and the COVID-19 pandemic. While every president and their administration have politicized science-based decision-making to some extent, the Trump administration's approach was notably different. The frequency of their attacks on science was unprecedented, as my colleagues and I documented during my time as a scientist with the Union of Concerned Scientists.
The consequences of politicizing science were starkly evident during the pandemic. The loss of life was significant, particularly in areas where public health guidelines were disregarded. These instances of scientific integrity breaches are not to be taken lightly, as they directly impact public health and safety.
However, these scientific integrity violations were curious given that many federal agencies had scientific integrity policies in place - many developed under the Obama administration. It became clear that many of these policies were not strong enough. In a prior analysis conducted with my colleague, Taryn MacKinney, we found weaknesses across many agencies scientific integrity policies. Based on this work, we crafted a roadmap for the next administration to strengthen federal agencies' scientific integrity and science-based processes.
President Biden’s memorandum on scientific integrity
On January 27, 2021, President Biden signed a “Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking.” The memorandum reflected many recommendations based on the roadmap my colleagues and I crafted. Key among those recommendations was forming a scientific integrity task force to research scientific integrity issues and determine what policy updates are needed.
An Interagency Task Force on Scientific Integrity was formed under the National Science and Technology Council (NSTC). As described by the EPA, “The Taskforce was a participatory process and comprised 57 representatives from 29 Federal science agencies, Federal statistical agencies, and 12 other Federal agencies that communicate and use science.”
The task force reviewed the effectiveness, or lack thereof, of scientific integrity policies and published its findings in January 2022. This report, a first of its kind, did a great job summarizing scientific integrity policies’ strengths and weaknesses. One of the report’s key recommendations was for the government to agree to a standard definition of “scientific integrity.” The report also suggested that agencies include a differing scientific opinion provision in their policies to allow experts who contributed significant work on an agency policy or rule to express a dissenting view if they wish to do so.
Based on its report, stakeholder input, and the input of its scientific integrity experts, the task force released “A Framework for Federal Scientific Integrity Policy and Practice.” This framework guides federal agencies in developing or updating scientific integrity policies and includes several metrics for regularly assessing and improving agency policies if needed. In its 66 pages, the framework is quite exhaustive and, in my opinion, deserving of high praise.
The memorandum did some other good, too!
In addition to forming the task force and its great work, President Biden’s memorandum also took some additional steps to strengthen scientific integrity. For example, the memorandum clarified that every federal agency needs a scientific integrity officer. The memorandum did this “because science, facts, and evidence are vital to addressing policy and programmatic issues across the Federal Government.” A scientific integrity officer oversees an agency's scientific integrity policy and practice implementation.
The memorandum also required agencies that conduct, fund or oversee scientific research to establish a chief science officer. The chief science officer, or chief scientist, oversees agency processes by which science is conducted or utilized. This includes scientific integrity, and the memorandum clearly states that the chief science officer is to coordinate with the scientific integrity official on all matters related to scientific integrity policies.
The parade of scientific integrity policies
We are beginning to see updated or newly developed drafts of scientific integrity policies. Are the policies actually following the framework? And are the agencies updating existing policies stronger? Let’s look at some draft policies to see.
The Department of Energy (DOE)
The DOE updated its scientific integrity policy on January 19th, 2024.
The prior version of DOE’s scientific integrity policy did not specify a process for submitting, investigating, and resolving allegations of scientific integrity. Unfortunately, the new version of DOE’s policy does not do this either. The policy does state that such processes are being developed.
DOE did not formerly publicly identify a scientific integrity official, and it appears that the agency still has not made this information publicly available.
DOE will need to continue to refine its scientific integrity policy following the scientific integrity framework.
Health and Human Services (HHS)
HHS published a draft of its updated scientific integrity policy in 2023 and opened it for public comment.
The prior policy was publicly available but was broad and vague. The new version of the HHS policy is considerably better and aligned with many of the metrics put forward by the scientific integrity framework.
The process of reporting allegations is still not detailed in the updated policy.
The updated policy includes information about differing scientific opinions and has charged its scientific integrity officer and council to develop a formal process.
Department of Labor (DOL)
DOL did release a new scientific integrity policy, although it is unclear exactly when this occurred.
The prior policy was not online or publicly accessible - the new one is available to the public.
The DOL policy includes and encourages differing scientific opinions. The prior policy did not mention differing scientific opinions.
The former policy and the current policy do not specify a process for individuals to submit allegations, although the updated policy calls on the scientific integrity officer to develop such a process.
While I will not break down what’s changed in the policies here, both the Environmental Protection Agency (EPA) and the National Oceanic and Atmospheric Administration (NOAA) have strengthened policies that were already quite strong in the first place.
It is clear from a glance at a handful of policies that some agencies have taken the time to consider needed changes to their scientific integrity policies. Other agencies have slapped the model policy in the scientific integrity task force’s framework on their website. That is not necessarily the worst thing to happen, but I’m going to guess that the task force did not intend for the model policy to be used in such a way. I would surmise the model policy was to serve as an example rather than an actual policy. The model policy is good, but it’s missing key details about processes agencies should add - I hope such additions are encouraged during future assessments.
Will these new policies prevent scientific integrity violations?
Yes. And no.
Scientific integrity policies, processes, and infrastructure establish a culture of scientific integrity that values science conducted and utilized free from political interference. The policies also provide confidential processes for scientists to report allegations to scientific integrity experts who investigate the issue and recommend accountability actions in case of a scientific violation. One hopes that this culture of scientific integrity preempts or unfurls any scientific integrity violations.
Unfortunately, political appointees often have the power to do what they wish. And agency policies are not law. This is why I, and many other scientific integrity advocates, have pushed for the passage of the Scientific Integrity Act. This bill was reintroduced on July 25, 2023.
If this bill is passed, many protections for scientists and their work would be codified so that political appointees could be held accountable for political interference in the science-based policy process. Additionally, the passage of the Scientific Integrity Act would make it difficult for any future administration to cut scientific integrity protections, which is not the case now. In 2019, the bill passed out of the House Science Committee with bipartisan support, so there is some hope that one day, our legislators will understand the importance of scientific integrity and codify it into law.
Until we have legislation passed, agencies’ new scientific integrity policies—and hopefully, the training that comes with them—will help agency staff better understand scientific integrity policy and practice and why it’s important. Because of President Biden’s memorandum and the work of the scientific integrity task force, we’re closer to having a strong culture of scientific integrity across the entire Federal Government. There’s still a lot of work to do, but that’s a huge step forward.