CSLDF Comments on the EPA Draft Scientific Integrity Policy

Last Friday, CSLDF joined 7 other organizations to urge the U.S. Environmental Protection Agency (“EPA”) to further strengthen its scientific integrity policy to better protect federal science and scientists.

The current federal agency scientific integrity policies are largely products of the Obama administration and were designed to help prevent misuse and abuse of federal science. But under the Trump administration – which saw a truly unprecedented number of attacks on science – it became clear that many agencies still lacked adequate safeguards despite these policies. In 2021, a week after taking office, President Biden ordered federal agencies to implement much-needed reforms, and agencies have recently started unveiling their new draft policies.

We appreciate the opportunity to provide feedback on this updated draft scientific integrity policy and applaud several elements of it, such as making it clearer that scientists have the freedom to speak outside of their official position with the agency. However, more work is needed to ensure more robust scientific integrity protections at EPA.

Specific areas for improvement include stronger deterrents to misconduct, such as more explicit procedures for investigating alleged violations and holding violators accountable (including political appointees and high-level officials); clearer definitions of what constitutes a conflict of interest; and stronger protections from retaliation or reprisal.

Other areas for improvement include more robust support for staff with scientific integrity responsibilities; involving career staff more meaningfully in scientific decisions; a clear means of recognizing and supporting other modes of science, such as citizen science; and a deeper commitment to diversity, equity, inclusion, and accessibility.

CSLDF offers a free series of guides to scientific integrity policies at the main U.S. federal scientific agencies. The guides are intended to help researchers understand and navigate their employer’s policy and indicate which agencies currently have strong scientific integrity protections – and which do not.

We commend the EPA on this first step towards improved protections for agency scientists and encourage them to take bolder steps to safeguard scientific integrity.

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