On June 22, the White House Office of Science and Technology Policy (OSTP) announced that it adopted its own, first-ever scientific integrity policy for the first time in history. CSLDF commends OSTP for finally adopting a scientific integrity policy—and setting an example for other federal agencies, who are expected to follow suit later this month with new or updated scientific integrity policies of their own.
CSLDF has previously provided comments to OSTP, including recommendations on how to improve agency scientific integrity and how to improve the scientific integrity framework. We’ve also created a model scientific integrity policy for federal agencies to look to when revising or creating their own policies.
OSTP has been tasked with improving scientific integrity across federal agencies but their progress thus far has been very slow, as we have previously noted, and we are thrilled that OSTP has taken the critical step of now issuing its own policy. CSLDF wishes to highlight some of the most important parts of OSTP’s model scientific integrity policy, including areas for improvement.
As an initial matter, we are glad to see that the new White House policy takes diversity, equity, inclusion, and accessibility seriously, and addresses the issue of agency culture. We agree with the policy’s stated acknowledgment that a culture of scientific integrity is only possible when scientists feel safe to raise issues of inequity or political interference.
To CSLDF, any scientific integrity policy with teeth must also address: (1) what is considered a violation of scientific integrity; (2) how and where to file a complaint; (3) what information the filing must contain; (4) how and by whom a complaint will be evaluated; (5) what the investigation process will entail; (6) mandatory deadlines for responding to complaints, completing the investigation, and publishing findings; (7) the right to a hearing; and (8) the parties’ rights of appeal and procedures for appeals.
Unfortunately, OSTP’s policy is missing many of these critical elements. While it does define a violation of scientific integrity, OSTP’s policy vaguely states that scientific integrity violations will be treated “comparable to violations of government ethics rules.” Unfortunately, it also does not explain how to file a complaint or give details about what complainants should expect, including whether there will be hearings, although it does briefly note there will be “an appeals process.”
The policy also does not address attempted violations of scientific integrity—only actual violations, including those due to “political influence or inappropriate influence.” As we have noted before, much damage can still be done even by unsuccessful attempts, so they must be clearly prohibited as well.
In better news, one of the most positive sections we saw in OSTP’s policy related to “ensuring the free flow of scientific information.” Among other things, the policy ensures that scientists can freely speak to the media or the public on their personal time without career consequences. It also requires that agency officials won’t ask, direct, or suggest that scientists alter the presentation of their scientific findings in a manner that could compromise the objectivity or accurate representation of those findings. This was a huge issue during the previous administration, and we are hopeful that OSTP’s new policy will prevent some of those same issues from occurring in the future.
Similarly, we were pleased to see OSTP protect government scientists by prohibiting “retaliation or reprisal” and requiring the White House to “comply with whistleblower protections.” For scientists who report violations of scientific integrity, the policy offers clear protections by considering any retaliation to be “inappropriate influence.” OSTP’s policy further requires that employees conduct scientific research “honestly and thoroughly, and disclose any conflicts of interest.” Taken together, these provisions will go a long way toward promoting the necessary culture of scientific integrity and protecting scientific processes.
Unfortunately, as we have mentioned before, we are still waiting for Congress to pass the Scientific Integrity Act to formally codify these protections into the law once and for all. OSTP has chosen to release its scientific integrity policy, with its strengths and weaknesses, but was not required by Congress to do so, and a future science-hostile administration could undo all of this progress. Congress must pass scientific integrity legislation and provide agencies with the authority and mandate to act when integrity is compromised.
Even so, this White House policy is an important step forward, and we are eager to review other federal agencies’ policies as they release them to the public in the coming weeks and months.