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.