REPORT OF THE QUALITY-SCIENCE TEAM
U. S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL PERFORMANCE REVIEW
August 6, 1993
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i C.-
Quality Science Team Members
Co-Chairs: Wil Wilson - OAR, i Bill Raub - OA
Tyrone Aiken - OPPTS
Kay Austin - OPPTS
Aabika Bathija - OPPTS
Timothy Backstron - OGC
Steven Bayard - ORD
Joseph Breen - OPPTS
Douglas Campt - OPPTS
Jose Cisneros - Region 5
Mary Clark - OAR/NAERL
Larry Cupitt - ORD/AREAL
Charles Kensley - Region 7
Steven Hedtke - ORD/Duluth
Dominique Lueckenhoff - Region 3
Edward Ohanian - OW
Ronald Patterson - ORD
Sally Perreault Darney - RTP
Rosemarie Russo - ORD/Athens
Stephanie Sanzone - OA/SAB
Rita Schoeny - ORD/Cincinnati
Robin Sega11 - OAR/RTP
Babasaheb Sonawane - ORD
Silvia Termes - OPPTS
Raaona Travato - ow
Darlene Watford - OPPTS
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TEL: . Rug 27.93 9:23 No.001 P.03
X. VISION
that USEPA be recognized throughout the world
as a science agency, as veil as a regulatory agency,
by virtue of
1) decisions consistently based on high-quality science;
2) leadership In all major areas of environmental science; 1 and
3) affective communication and coordination of environmental-
scientific Issues and policies.
ZZ. BACKGROUND/CURRENT STATE
Rule-Baking and other policy decisions at USEPA almost invariably
rely on science, with the nature and extent of that reliance varying
considerably from one instance to another. But one factor is
invariant: quality must be a first-order concern in deciding what
scientific information is relevant, how it is presented, and how: it
is used. Quality science is a condition precedent for quality
decisions.
USEPA's science activities range from fundamental, basic research to
highly applied, problem-solving efforts. Basic research may be
driven by critical, media-specific environmental problems; or it may
create the foundation for unprecedented, multimedia approaches to
the nation's most critical environmental challenges. While applied
research may be used to fulfill immediate needs, it may also
contribute to attaining long-term strategic goals.
Scientific activities at USEPA are performed both by its research
laboratories and by its program and policy offices2. These
activities directly impact the national and international environ-
mental-science community. For example, USEPA's analytical methods,
predictive models, and risk-assessment guidelines are used as
standards by other agencies, both nationally and abroad.
USEPA is on the cutting edge of many areas of environmental science.
and contributions of its scientists and other technical personnel
are respected world-wide. However, the role of quality science in
USEPA policies, decisions, and actions is often questioned. USEPA'«
major agenda is unquestionably that of a regulatory agency charged
1 Toe words In this text are Intended to be inclusive, not exclusive. 'Environmental science* is used
from a holistic perspective, encompassing both ecological science and human health science. "Science*
(and 'scientists") is used to represent not only the traditional natural sciences, but engineering (and
engineers), the mathematical sciences, and the many other sciences (e.g., economics, social sciences) thai
nay become more and more important over the next decade.
* References to "program and policy offices" in this document are intended to address both
Headquarters and Regional operations.
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with promulgation and enforcement of air-, water- and land-quality
statutes. Science often is — or seems to be — a secondary
priority. Zn fact/ USEPA decisions all too frequently are perceived
by OMB, Congress, other Federal agencies, industry, or the public as
not grounded in sound science. To the extent that the Agency does
not support and use quality science, this perception will be
repeatedly reinforced.
USEPA's ability to conduct an effective and coherent quality-science
prograa is impacted by numerous congressional mandates and highly
compartmentalized appropriations. Program offices within USEPA are
divided by media-specific statutes that sometimes erect seemingly
insurmountable barriers to cross-media initiatives. Moreover, about
75% of the budget is directed toward problems of high visibility and
relatively low risk rather than to environmental concerns considered
by the scientific community to present significantly greater risks
to human health and the environment (Problem Area Analysis of the
FY94 Budget, OPPE, June, 1993).
Another manifestation of this balkanized governance is that the
Agency's research and development is not driven by a holistic, long-
term, strategic plan. Instead, program offices, dependent upon the
Office of Research and Development (ORD) for support of regulatory
actions, have seen critical research cut back substantially or
eliminated outright, as ORD is forced to respond to new policy
mandates without a commensurate increase in funds and staff.
Neither ORD laboratories nor the program offices historically have
had sufficient resources to address allvhigh-priority short-term
needs and a substantial long-term research agenda simultaneously.
Contributing to the perception that USEPA's decision-making is not
always rooted in sound science is the Agency's severely limited
ability to support and nurture its scientific staff. There are
numerous inconsistencies throughout the Agency regarding job
functions, training and development, opportunities for advancement,
and recognition for scientists. In the face of attrition and loss
of institutional memory in specific subject-matter areas, the Agency
has fallen behind with respect to training and career development
programs for its technical staff. Further, reductions in science
and engineering career positions not only have bred undue dependence
on contractors to meet scientific and technical needs but also have
encumbered USEPA scientists increasingly with contracting duties —
thereby shifting their focus and their talents away from science
toward administration.
Ineffective communication between USEfA policy-makers and scientific
staff also tarnishes USEPA's reputation with respect to science.
Evaluating and communicating the sources of uncertainty in
predictive exposure and risk assessment are not deeply ingrained
practices across the Agency. Scientists do not always fashion their
recommendations and/or risk assessments so that all major
assumptions and findings are made explicit. Likewise, many managers
do not frame their questions to enable scientists to address the
issues in the best way. Neither risk assessors nor risk managers
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TEL: Rug 27.93 9 = 23 No.001 P.05
consistently convey their findings, decisions,, and the associated
uncertainties using the language and communication tools most
appropriate* for the target audience. USEPA cannot be said to be
fulfilling its mission if it cannot adequately convey levels of risk
to the public.
Communication and coordination among USEPA's science programs —
both internally and externally — are beset by problems as veil.
Inadequate coordination among programs and'fehe laboratories has led
to science being practiced in isolation, and perhaps, redundantly.
There is no comprehensive, cross-referenced data base that
identifies in-house expertise and on-going activities for access by
Agency scientists. Scientists working on similar or closely related
issues or projects find difficulty in establishing peer review and
support elsewhere within USEPA because there is no accessible
Agency-wide listing of scientific personnel, training, and
expertise. The same applies to USEPA publications, scientific
findings, and decisions.
Communication and coordination of efforts with scientists in other
Federal and State agencies and international organizations also-are
inconsistent. USEPA research efforts often have no apparent impact
on the. research agendas of other agencies, nor is there a well-
established mechanism for USEPA staff to access the results of their
counterparts at other agencies. while there are examples of
successful collaborative efforts between USEPA and industry, (such
as pollution prevention and product stewardship,) interactions with
academia and industry should be considerably strengthened.
Inflexibilities in the contracting mechanism, relative to contract
types, inhibit the Agency's ability to adequately address specific,
research needs. Currently, the governing process for all contracts,
whether scientific or non-scientific, is the same. Laboratory
scientific and technical staff are required to purchase equipment
utilizing the same procurement criteria as staff with completely
differing needs. Due to the vastly differing nature of laboratory
scientific needs from other types of procurement needs, utilizing
universal procurement criteria for both of these areas greatly
stifles the timely actions and operations of laboratory scientific
and technical staff.
Against this sobering backdrop of needs, opportunities and problems,
USEPA must take deliberate steps if it is to achieve its vision of
being recognized as a science agency. The remainder of this
document presents an overall strategy and some specific proposals
toward that end.
III. DESIRED STATE/GOALS
Not only can science support the over-arching environmental-
protection strategies of today; it also can define the strategies of
tomorrow. Thus, changes in the way USEPA staff do science should
include, but not be limited to, a greater emphasis on the following
strategic themes: risk-based priority setting; pollution
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prevention, ecosystem approaches, and product stewardship; and
environmental education and equity for all population groups
Underlying it all should be a strong, sustained program of basic and
applied research in all major domains of environmental science.
• Cross-media issues
Today, environmental issues are more complex than ever before; and
environmental protection strategies must cut across all
environmental media and all routes of exposure. Rarely is it
sufficient to deal with environmental media individually. Rather,
the quality of science across all program offices that exercise
statutory authority over specific media should reflect a consistent,
holistic approach to protecting and enhancing both ecosystems and
human health and, at the same time, should ensure adequate
environmental resources to meet future needs.
• Quality data and application
To ensure that science within USEPA is of the highest quality, USEPA
must improve the quality of data and promote its appropriate
application in decision-making processes. This can be accomplished
by improving the methodologies used to acquire data; ensuring that
models properly reflect the latest scientific information, data, and
concepts — including uncertainty analysis; applying models
responsibly and consistently; and incorporating current scientific
knowledge into risk-based decision-making.
• Communication and Coordination
Effective communication and coordination among USEPA scientists,
between scientists and policy-makers, and between the Agency and the
rest of society are essential to achieve high-quality science.
USEPA must improve across the board in this area. Interactions
between risk managers and risk assessors warrant special emphasis,
as do USEPA interactions with other federal agencies, state and
local agencies, OMB, Congress, academe, industry and international
organizations. Above all, the Agency must improve its communication
to the general public.
e Recognition and Resources
Public recognition, including that of the Congress, is essential for
USEPA to achieve the above vision. USEPA requires not only
effective environmental legislation but also resources sufficient to
identify »isk-based priorities and to implement appropriate
environment protection and research strategies. USEPA's resources
must also include a well-trained, well-equipped, and highly-
motivated scientific and technical work force.
• Planning
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Strategic planning and appropriate resource allocation are necessary
to ensure: 1) the success of both short-term and long-term projects
and 2) adequate environmental protection for the future.
Ultimately, US EPA can do the right science and do the science right
only when the policies, methods, and infrastructure, as veil as the
public, actively support the undertaking.
XY. TARGET/ACTION
To achieve its vision that quality science undergird all
environmental decisions and to strongly support its leadership role
in all areas of environmental science, USEPA must identify those
elements forming the basis of credible science and make a commitment
to implement specifically targeted initiatives to achieve the
vision. Broadly interpreted, a quality science agenda addresses the
following:
• Clearly identifies and prioritizes the most important scientific
questions to be addressed;
• Identifies and uses the most appropriate and powerful
experimental and analytical designs;
• Employs state-of-the-art experimental techniques;
• Makes accurate measurements to generate reliable data;
• Evaluates and interprets the results appropriately to obtain
accurate answers to the questions;
• Uses the results in mathematical models to apply science
knowledge efficiently and coherently;
• Subjects the methods, results, interpretations, and models to
field validation and independent review processes; and
• Provides an infrastructure that recruits, retains and rewards
high quality scientific personnel and an on-going core
capability.
V. TARGET/ACTION CATEGORIES
Development and implementation of an Agency-wide quality science
agenda can be accomplished through the target/action areas and
associated do-ables/initiatives that are summarized in this section.
Details on each of the do-ables/initiatives are presented in the
next section.
A. ACHIEVEMENT OF QUALITY SCIENCE IN USEPA
TARGET/ACTION STATEMENT: Over the last few years, several expert
panels have conducted thorough reviews of science at USEPA (e.g..
Safeguarding the Future; Credible Science. Credible Decisions.
Reducing Siaki Setting Priorities and Strategies for Environmental
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Protection, and Future Risk; Research Strategies for the .
These panels have Identified what needs to be done to improve both
the quality and the relevance of science at USEPA. Now, USEPA's
leadership needs to implement the recommendations.
Several recommendations have consistently emerged from the expert
panel reviews: (i) To deal effectively with today's complex
environmental problems, the Agency needs to develop a coherent
science agenda that moves toward cross-media, anticipatory research;
(2) the Agency should take steps to ensure that qualify science
enters the decision-making process early and consistently for
effective environmental protection programs; and (3) Agency
leadership Bust undertake a deliberate and continuing effort to
create the climate, culture, and incentives necessary to encourage
superior science.
SPECTFTC
1. Quality-Science as a Continuing Policy Objective
2. Procedures that Promote Scientific Excellence
3. Science Advice within Program and Regional Offices
4. Science/Congressional-Liaison Team
B. THE SCIENCE/POLICY INTERFACE
TARGET/ACTION STATEMENT; Efficacious use of science in support of
policy decisions is the responsibility of both policy-makers and
scientists. The credibility of USEPA decisions, the efficient use
of USEPA resources, and the cost-effectiveness of USEPA regulations
are all critically dependent on the maintenance of a clear
distinction and a proper balance between science and policy. The
place where scientific analysis ends and policy choices begin is not
always easy to determine. In the context of a regulatory agency
with many pressing responsibilities, the tendency to blur the line
between science and policy is difficult to resist for scientists and
policy Bakers alike.
The key to crafting and maintaining an appropriate relationship
between scientific inquiry and policy making is the nature of the
interaction between policy makers (or "risk managers") and
scientists (or."risk assessors"). The timing, frequency, and nature
of such communications are all important. Scientific analyses that
are informative and policy decisions that are informed can best be
achieved through implementation of specific practices and procedure*
governing communication across the science/policy interface.
SPECIFIC PQ-ABLES
1. Preparation of Policy-Makers for the Science/Policy Interface
2. Preparation of Scientists for the Science/Policy Interface
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TEL: flug 27,93 9 = 23 No.001 P.09
3. CASE BOOK on the Science/Policy Interface
4. Management of Differential Risks among Population Subgroups
C. WURTURING QUALITY SCIENTISTS
TARGET/ACTION STATEMENT: As USEPA works to advance the high-
quality performance of science and technology in its organization,
it aust develop, increase and support the skills and talents of its
scientific workforce.
SPECIFIC PO-ABLES
1. Job enhancement and Resource Support for Scientists
2. Career Ladders and Promotion/Incentive/Reward Systems
3. Employee-Empowered Scientific Recognition Committee
4. Training For Scientists
5. Recruitment of Scientists
D. COMMUNICATION AND COORDINATION
TARGET/ACTION STATEMENT; USEPA has the responsibility to
communicate its environmental scientific findings to properly
reflect the high-quality scientific basis for decisionmaking.
Communication of findings and decisions must take into account the
specific audience for whom the information is intended and include
the appropriate language and tools to attain the most effective
results. The Agency must coordinate its activities to avoid
replication of tasks and attain coherent products (regulations,
guidelines, regulatory decisions, research findings). Risk managers
and scientists must establish good communication to ensure that
regulatory decisions are based on high-quality science.
SPECIFIC DO-ABLES
1. Prioritization of Intra-Agency Communication and Coordination
2. Exchange of Scientists (internally 4 externally) For Purposes
of Exchanging Science
3. Communication and Coordination with Other Federal Agencies,
State and Local Agencies, and International Organizations
4. Communication and Coordination with Academia and Industry
5. Communication and Coordination with Congress, OMB, News
Media, and the General Public
72. DO-XBIES/INITIATIVZS
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A. Achievement ef Quality Scienca in USEPA
A.I Quality-Science as a Continuing Policy Objective
VHATi Make a public commitment to use and support high-quality
•cience in all of the Agency's deliberations and actions.
This would consist of several actions:
(1) The Administrator would publicly adopt the vision
statement of the Quality Science Team and commit the
Agency to accomplishing the vision statement.
•
(2) The Administrator would establish a process by which to
implement the changes needed to ensure that USEPA is a
science agency with high-quality science underpinning all
of its actions.
WHOi The Administrator must publicly affirm the vision for quality
science at USEPA. She must also establish and empower the Agency-
wide Committee for Quality Science, and task it with overseeing the
Agency's "deliberate and continuing effort to create the climate,
culture, and incentives necessary to encourage superior science.!1
TZMZ LIKE: One legacy of the National Performance Review should be
the establishment and empowering of an Agency-wide team, a Committee
for Quality Science, to develop and implement policies and
procedures to enhance Quality Science at USEPA. This Committee for
Quality Science should be part of USEPA's' effort to "reinvent1* the
Agency. The Committee will be "continuing", providing suggestions
for changes and assessing progress made in improving quality
science. The Committee should incorporate and build upon efforts
already underway, including the Council of Science Advisors, the
Sci/Tech Committee, and the Quality Science Team itself.
BARRIERS: There is skepticism that USEPA, with its regulatory role,
can also be a "science" Agency, overcoming this skepticism within
USEPA itself, in the Administration, and in Congress will be a major
challenge. Adoption of the vision statement by the Administrator
will not be adequate to bring about needed changes: the same vision
Bust also be shared by the AAs and other upper- and mid-level
managers. Demoralizing rumors of lab consolidation should be
replaced by better administration of decentralized science.
Finally, the vision must bring about changes in attitudes and
actions.
COSTS: There are no additional costs to be incurred by having the
Administrator affirm the vision statement and establish a Committee
for Quality Science to advise her. Undoubtedly, some actions
recommended by the Committee to improve the "climate, culture, and
incentives" will have investment costs: quality science does cost,
both in terms of funds and personnel. Nonetheless, there are a
number of specific recommendations can be accomplished with no
additional costs.
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BENEFITS: The benefits to supporting the quality science vision are
significant. Quality science used to support Agency decision-making
will increase Agency credibility with the scientific community, the
public, impacted industries, and Congress. Improved credibility of
USEPA as a science organization with Congress and OMB will likely
lead to increased resources and greater flexibility. The recogni-
tion resulting from increased public confidence will improve work
force morale, which will, in turn, provide further improvements in
the Agency's rules and decisions. Only when high-quality science
undergirds the Agency's deliberations can more effective and less
costly solutions be identified. Better solutions to environmental
problems will provide significant savings to the affected industries
and will improve the national economy while still protecting our
health and ecology.
MEASURES 0? SUCCESS: This initiative will be successful only if the
vision is put into action. The ultimate goal is to improve the
quality of the Agency's science — not quantity — and quality is
much more difficult to measure. Actions recommended by the
Committee for Quality Science should each contain their own measures
of success. The success of the overall effort to improve-the
quality of science can be estimated through periodic surveys- of
public (including scientific community, affected industries, and
Congress) perceptions and confidence in the Agency's decisions.
A.2 Procedures that Promote Scientific Excellence
WHAT: Reaffirm USEPA's commitment to basic scientific research,
peer review, quality assurance, Good Laboratory Practices, and other
policies that are designed to promote excellence in science.
Sustained excellence in science does not come about spontaneously.
Quality science must be promoted regularly across the Agency through
the application and continuing refinement of procedures created
especially for this purpose.
WHO: Administrator, Assistant Administrators, Regional
Administrators, Council of Science Advisors
TIKE LINE: continuing; evaluate progress after 5 years
BARRIERSt Although the vast majority of USEPA managers and their
staffs advocate quality science in principle, considerable
disagreement remains as to how that goal can best be achieved. Many
regulatory officials are concerned that, in some instances, expanded
use of peer review and the other quality-promoting procedures will
constrain operations unduly or require unnecessary expenditures of
time and noney. Further, even in instances when managers are eager
to invoke these procedures, budgets and staffing constraints often
preclude it. There is currently more emphasis on administrative
procedures than on achieving flexibility.
COSTS: No adequate basis exists for estimating the absolute costs
of this proposed initiative. Historical USEPA-wide records for
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budgets and staffing levels do not break out the costs associated
with oeer review and the other quality-promoting procedures. OARM,
in cooperation with the program offices, ORD and the Regions, should
begin a systematic review of the current dollars and FTEs that
constitute the current operating level of these quality promoting
activities. An estimate of the FTEs and dollars needed to eliminate
the operating shortfall and a short-term strategy for shifting
resources would be developed and implemented over 18 months. After
the shortfall is erased, a systematic, nulti-year effort to increase
the scope and intensity of the quality-science thrust could take
place.
BENZ7XT8I Broader' and more intense promotion of excellence in
science will be nanifest almost immediately in the quality and
credibility of the technical work-products that support decision-
Saking throughout the Agency. This should lead to regulations and
policies that are cost effective and thus gain broad acceptance from
the regulated communities. And, if decisions are easier to
understand, less likely to invite legal challenge, and less likely
to be reversed in court when challenged, then costs of litigation
and enforcement should go down.
MEASURES OF SUCCESS: Success would be indicated by progressively
more numerous decisions that win broad support for their
cost/effectiveness in achieving environmental protection.
A.3 Science Advice within Program and Regional Offices
WHAT: Continuing the development of a strong science advice program
within the Agency.
One role of science in EPA is to reduce uncertainties in
environmental decision-making. Because laboratory-animal testing is
the nodel used most frequently to predict the potential for human
health effects due to exposure to a chemical pollutant, there is
uncertainty in extrapolating from effects seen in laboratory animals
to predict effects in humans. Other areas of uncertainty in policy
decision-making arise as a result of limited knowledge about
exposure and the effect of numerous chemicals or chemical mixtures
on environmental components.
While policy decisions require a strong science base to reduce
uncertainty; USEPA policy or regulatory decisions are often
Shelved is not based on the relevant science. The science advice
Knc?ion? ensuring that policy decisions are based on • c ear
understanding of the relevant science, is currently not well-defined
S? systematically organized within USEPA. This would fnv'ude a
science advisor within ORD, each program office «nd region. The
science advisor'* function, analogous to that of an occ legal
advisor to a specific project or program, is to ensure 'that USEPJ
policy decisions and regulatory actions are based on «uP«r^
Science and a clear interpretation of relevant science and are
scientifically defensible.
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The science advisor within ORD, each program office and Region
should be a senior scientist or recognized expert who works closely
with the Science Advisor to the Administrator and serves as a
program-office liaison to the Agency's Science Advisory Board.
WHOi Science Advisor within ORD and Each Program Office
TIKI LINZi Develop and implement plan by fall 1994
BARRIERSi Decision makers nay object to what is perceived as an
additional layer of bureaucratic oversight. Programs which do not
function in traditional line management approach may find the
additional review inefficient in meeting statutory deadlines.
Resource allocation for science advisor positions may compete for
continuing education, training, and travel for program office career
scientists.
COSTS: Variable, but a senior scientist or science expert may
require GM/GS-15 and above salary range.
BENEFITS: The development of a strong science advice program within
the Agency would result in consistency in Agency policy decision-
making and the perception that USEPA is a "science" Agency.
Decisions in one program office would not adversely impact those in
other program offices. Another benefit would be more direct use of
ORD science and less reliance on contractors to program offices.
Career scientists would view their contribution to science at USEPA
as valuable, if work products were reviewed by a well-trained peer.
This would increase morale and incentives to do superior science.
Then the public would be less likely to challenge USEPA policy
decisions, avoiding costly delays (economic and environmental
quality) in implementation. Additionally, enhanced career
development and recognition would be provided for career scientists,
both vithin and outside the Agency, for their contribution to
excellence in science.
MEASURES OF SUCCESS: Policy decisions based on clear interpretation
of science leading to more consistency in decision-making. Public
support, news media perception enhanced, state and local
environmental sectors support USEPA decisions. Congressional
support, increased resource allocations.
A. 4 geienee/Congrsssional-Liaison Team
WHAT: Establish a Congressional-liaison team representing Quality
Science throughout the Agency.
The team would communicate actively with Congress and its staff
about important issues of environmental science. Science issues
should be communicated by scientifically-trained experts, not left
solely to Public Relations personnel. USEPA should identify topic-
area technical experts, train them to interact with Congress, and
encourage them to communicate with Congress about their areas of
technical expertise. Only when Congress and their staff understand
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T£|_: nug^r.ao y • ^ J H u . u« i r . . - •
the scientific and technical issues behind today's critical
environmental problems can they deal effectively with these complex
environmental problems. USEPA scientists should play a major role
in educating Congressional staff about environmental science.
WHO: The Assistant Administrator for Research and Development,
together with the Science Advisory Board, should champion this
•ffort; however, the team should represent the interests of science
throughout the Agency, including the Program Offices and Regions.
Topic-area *experts should be drawn from all sectors of the Agency.
TIKE LINEi The liaison staff would be established as part of the
National Performance Review effort to reinvent government and should
remain a permanent part of USEPA.
BARRIERS: There are possible legal restrictions against "lobbying"
Congress. Controls may need to be established to ensure that this
initiative is clearly a component of public education, outreach and
communications. Other science agencies seem to be able to use
articulate, respected scientists to communicate effectively with
Congress: USEPA should do no less. Potential barriers may be
overcome by using NOAA or NASA as a model.
COSTS: Costs will be minimal. Current public relations or liaison
staff could be re-assigned and augmented with a few additional FTEs.
Topic-area experts would be recruited from current scientific staff,
trained to communicate effectively with Congress and the public at
reasonable costs and provided travel funds. The topic-area experts
would not be permanently assigned to the Liaison Team, since they
have to remain involved with their research programs in order to
retain their expertise and credibility. Programs sponsored by the
liaison staff (for example, periodic briefings for Congressional
staff on critical environmental issues) should not be expensive.
Travel costs for regular visits by topic-area experts to USEPA
Headquarters and Congress could be absorbed within the Agency's
current budget. •
82VZ7XT6: Two major benefits will be: enhanced recognition by
Congress of the high quality of scientific and technical expertise
present in USEPA; and improved environmental legislation. USEPA has
the foremost experts in many areas of environmental science, and
this effort will help them be recognized for their expertise by
Congress, other federal sectors, and the public. . As USEPA becomes
respected as a science agency by Congress, it will be treated more
like a science agency. This effort v*!! also help educate Congress
(and Congressional staff and the public) about the scientific issues
involved in today's environmental problems. Such increased
understanding, together with the availability of identifiable topic-
area experts to provide counsel and advice, should make for better,
aore-effectiva, and less-costly environmental legislation.
Legislation that is well-founded in science will provide substantial
savings for the U.S. through more effective programs with fewer
ineffective, but costly, controls. Better legislation will also
save considerable time and effort by reducing the political battles
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entailed in frequent revisions and re-authorizations of
environmental legislation.
KEXSUR2S OF 80CC888: The goal of enhanced recognition of USEPA as
the premier environmental science agency by Congress and
Congressional staff can be assessed through periodic surveys
Success should also be reflected in increased requests for Agency
scientists to testify before Congress on technical environmental
issues.
B. Science Policy
B.I Preparation of Policy-Makers for the Science/Policy
Interface J
WHAT i Establish a training program to help policy makers
communicate more effectively with scientists.
EPA policy makers may fail to indicate the specific technical
questions that need to be answered to achieve a particular risk-
aanagement objective; and scientists charged with preparing relevant
analyses may fail to seek such clarification. Even when both
parties are of one mind as to the key questions, the decision-making
process often does not allow sufficient time for scientists to
prepare a thorough assessment. Moreover, scientists rarely have the
opportunity to help determine how their analyses actually are used
to shape policy.
When any of these scenarios occurs, EPA science is not kept in the
decision process. Over time, some scientists have come to feel that
they are not an integral part of the decision-making process. The
latter is a commonplace outcome whenever scientists focus on issues
they personally believe are important and later learn that the risk
managers consider those issues to be peripheral to the main
question (s) .
WHO: Agency-wide work group appointed by the Administrator; review
by Council of Science Advisors
TIKI LXHEs Training program should be developed and instituted by
the spring of 1994.
BAARIERSt The idea of yet another training program may meet
resistance in principle, especially from those who feel that prior
efforts in other subject-matter areas such as Total Quality
Management have diverted staff from important work without
commensurate positive effect on the quality of the decisions being
nade. Others may believe that the recommended training would merely
restate at length ideas that really are only common sense. still
others may fear that, by adopting the recommended communication
practices and procedures, they would be inviting unwarranted
incursion into their programmatic discretion.
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Policy makers will need to be assured that the 'objective is not t«
lrl£*nt S?:Jr decHi8Kior»a*i"9 prerogatives but rather ?o en™re !
proper relation and balance between science and policy. TO promote
cooperation by policy makers in the training, it Bust incorporate
substantial flexibility and use the time of policy Sakers
efficiently. The best time for an individual to take theVSpoHS
"
4 Jhf C08t °f d«v«l°Pi"9 the training program would be
approximately one person-year of effort. This could be accommodated
within the normal duties of the staff involved. wnca««a
BENEFITS: If policy makers were to make even modest modifications
in their standard practices and procedures in response to the
recommended training, the benefits could be very large. When
scientific analyses are properly focused on the precise questions
presented by the enabling statute or regulations, the resultant
decision will be less vulnerable during judicial review, scientists
also will be more productive and not waste time and resources ~on
peripheral issues. If outside scientists and the public believe
that EPA scientific analyses have not been unduly influenced by
policy/political requirements, the credibility of EPA decisions will
be enhanced. Moreover, the benefits to the public of even a single
regulation or action that is more cost-effective in achieving
Environmental goals than otherwise would have been the case in the
absence of the proposed training program would far exceed the cost
of developing and implementing the proposed program.
MEASURES O? SUCCESS: Because the recommended procedures for
communication across the science/policy interface are largely
objective, specific decisions can be examined to determine whether
policy nakers and scientists .have followed them. For example
scientists can be asked whether they were advised early in the
regulatory process concerning the specific questions their analyses
should focus on. In addition to such objective measures, changes in
attitudes will also be important. If the program succeeds
scientists will be less likely to complain that their work has been
distorted by policy requirements and policy makers will express
greater confidence in the objectivity of the analyses they receive.
This would result in a more coherent and relevant research agenda.
8.2 Preparation of Scientists for the Science/Policy Interface
WHAT: Establish a training program for scientists to assist them in
communicating effectively and appropriately with policy makers.
USEPA needs the best scientific and technical information to make
credible and scientifically defensible decisions. To ensure that,
the scientist must present to the policy maker a comprehensive risk
characterization (scientific analysis) and not just numbers.
The scientist must present both the qualitative and quantitative
features of the assessment and also identify any uncertainties in
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the assessment based on confidence in the data and methods used to
develop assessments. The scientist should present consistent
assessments of risk ranges, principal assumptions SnS
, upons n teir
underlying rationale. Also, where possible, he/she should quantify
the uncertainties along with comment about their influence on the
The policy nakers should specify whether the traditional scientific
extrapolation models are appropriate in specific cases; strive for
e55^pee? r"viev' both inter- and intra-agency; and identify when
additional information would be beneficial. Scientists should
stress that the risk assessment process employs a varying number of
judgmental positions to help bridge gaps in data and in
understanding of underlying biological processes. Risk assessors
should not attempt to overstate or understate risks, but rather oive
estimates and the range of uncertainty.
WHO i Agency-wide work group appointed by the Administrator;
review by the Council of Science Advisors
TIME LINE: Develop the guidance by fall of 1993.
BARRIERS: Some policy makers seem reluctant to interface with
program office or ORD scientists prior to communicating major risk-
based regulatory decisions to the public. Also, they may choose not
to reveal the degree of uncertainty or what influence uncertainty
had on their final decisions. At times, scientists are not given
adequate time to collect acceptable data to perform credible
assessments. Research scientists are often brought into the process
very late, as reviewers, rather than early on, as developers. At
times, USEPA is pressured by external forces into making rush
decisions that are not based on good science. Many times scientists
are not advised what specific questions the decision makers need
answered early on in the process. Some policy makers are resistant
to involving scientists in the decision making process because of
their perception that scientists should be excluded from risk
management-based policy decisions.
COST: $100,000 for workshops, consultants and contractor assistance
to develop the guidance document (s).
BENEFITS: Adherence to Agency wide guidance will improve the
understanding of Agency risk assessments, lead to more informed
decisions, and improve the credibility of Agency assessments and
decisions and ultimately decrease costly challenges to regulations
and enforcement actions. Recognition of USEPA risk assessments will
improve scientists morale which in turn will lead to their enhanced
productivity.
MEASURES or SUCCESS: Decisions based on credible risk assessments
will decrease the number of challenges from environmentalists,
industries and the public.
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8.3 CASE BOOK on the Science/Policy Interface
WHAT: Create CASE BOOK, a collection of agency cases documented
~
Exemplary cases of science and policy interfacing.
Examples of problem solving approaches.
Orientation workbook for risk assessors and risk managers.
A guide to help new employees assess and manage risks.
A primary reference for science/policy approaches.
WHOi Council of Science Advisors. Contributions to CASE BOOK will
be prepared by each program, that is, the offices serving under the
various statues, (e.g., TSCA, FIFRA, etc.). 9
TIME LINE: Continuing; evaluate program after 2 years. The time
for completion of the first edition of CASE BOOK will be one year
after the agreement that this proposal is to 'be accepted and
Implemented. Approximately, September 1994.
BARRIERS: Some risk managers and risk assessors may be reluctant to
relinquish their analysis for agency wide review. Additionally, a
manual that is circumspect of decisions may cause paralysis of
analysis, that is, CASE BOOK may cause risk assessors/managers to
equivocate rather than make well-timed decisions. These are common
barriers and should not prevent the idea of the CASE BOOK from being
successful. Most scientific organizations compile reference
information for use when making risk assessments and doing
research/experiments.
COSTS: $25,000 for consultants and publication assistance.
BENEFITS! Circulation of a high quality manual containing
instructive Science and Policy Case Studies will benefit the agency .
CASE BOOK will provide substantive examples of what is expected of
risk assessors and risk managers. Specifically, risks assessors and
risks managers who know before hand what is expected of them have an
advantage over those that do not. Communication is critical in
order to facilitate problem solving. CASE BOOK will be a lexicon of
Science and Policy and reveal the process of science and policy
interfacing. r '
•
A well-prepared inventory of science and policy issues will require
few resources compared to the benefits. Circulation of exemplary
science and policy decisions will raise the morale of Scientists and
Policy makers. The agency standards will be open to scrutiny and
forced to stand the test of critique from agency scientists and
policy nakers. The peer review process, good laboratory practices
and other practices designed to promote quality science would be
enhanced by CASE BOOK. Promoting quality science and policy
interfacing and publishing examples will gain support from the
Congress and the public through better risks communication.
17
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TEL: Pug 27,93 9 = 23 No.001 ?.19
CASE BOOK will be an excellent tool for orientation of Risk managers
and Risk assessors, both new and existing employees. In concision
the substance of CASE BOOK is already contained within the
used and cited in the continual efforts to manage and asselJ risk
Feedback and input into CASE BOOK will identify the effectiveness of
the document. Commentary sections on each case cited in CASE BOOK
SS5dJ!S?l?Wl*??tJtht ««"tiveness of the document. Similar-Tv °*
CASE BOOK IS Cited as a guideline in future examples of Science and
C9UCY Interface in the agency. we will know it is working.
Subgroups *a"geBent of »i«««ntUl Risks among Population
WHAT! Enhance the capabilities of health-risk assessors to
differentiate among population subgroups wherever practical by
developing a long-term research plan and associated risk-assessment
strategy.
Attempts to estimate the likelihood of adverse human-health effects
from known or putative environmental hazards traditionally have
focused on the risks faced by the population on the average; the
principal exception has been selected reference concentrations or
doses that are calculated using arbitrary uncertainty factors to
protect potentially sensitive populations. yet experience
increasingly is making clear that, for any given hazard, some
population subgroups may be at substantially greater risks than
others as a consequence of stage of development, gender, or other
manifestation of genetic make-up. Moreover, current research in
cell biology, molecular genetics, and epidemiology is offering
evermore powerful means to assess subgroup-specific risks; and an
jxpanded •ffort would yield significant return. The time has come
for USEPA risk assessors, as well as the other scientists whose work
supports them, t.o obtain and use subgroup-specific data wherever
practical as a matter of policy.
For example, in view of the possibility that infants and children
aay be a greater risk from certain pesticides than are adults, the
National Academy of Sciences recently recommended revamping the
pesticide-registration process so that it includes better tests and
better data relevant to this subgroup. This line of reasoning can
be extended to include the possible differential vulnerabilities of
infants and children to hazards other than pesticides. And
essentially the same logic can be applied to other population
subgroups under various circumstances — especially the elderly
women, and racial and ethnic minorities — for a wide spectrum of
environmental hazards.
WHO: The Administrator could appoint an agency-wide working group to
develop a two-part product: (l) a research agenda to expand the
10
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knowledge base relevant to subgroup-specific risks and f•>^
TIKE LZKEi Appointment of working group by January, 1994.
^
costs and time required for risk assessments could rise unduly
COSTSi $100,000 for a workshop and consultant fees related
developing the research agenda and upgrading !in?mm
strategy. USEPA staff costs' would be absorbed Is 'part '""
BENEFITS: The initiative would introduce a new level of scientific
rigor and sophistication into health-risk assessment Trie
initiative also would stimulate research toward better tests and
better data pertinent to differential risks. Subgroup- spec if *ic 'risk
' ° btter tailorin9' of protuepct?v measure's
f * measures
J!*i?£ y?CJ£l 1eedS °f vulne^abl« subgroups, to improved public
health, and thus to more cost/effective regulation. P^DHC
MEASURES OF SUCCESS: Progressively more emphasis on subgroups in
of
C. MurturinQ Quality Se
C.I Job Knbaneemeat and Resource Support for Scientists
to
* K in Pronotin9 quality science at USEPA is to ensure
that th« jobs we create are of high quality - stimulating
rewarding,. and as free from administrative distractions as pSssibll'
This Bay require shifts in job assignments among other components of
the work force. More scientific projects should be done in-hSSse to
enable our scientists to share scientific contributions and to link
science to Agency policy, rather than merely reviewing the work Sf
others, as with contract activities.
* BU8t; fin$V5e that' as W€ nurtur« quality scientists
SIMM * Ve prfvid« th
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TEL: Rug 27.93 9 = 23 No.001 P.21
procedures? ^ pr°Vided f°r lamenting these standards and
WHO: Scientists and engineers throughout the Agency
TIKE lIMEi By fall of 1994, review all relevant job assignments-
develop and implement plan to decrease reliance on contract lupport •
develop and implement set of standards and QA plans for scientific
rMOV* instit^io"^ barriers to
BARRIERS: There are currently many inconsistencies throughout the
Agency on the functions and grade levels of scientists. Although
ORD has a career advancement systera in place, it cannot be applied
to other USEPA program scientists due to differing duties and
functions. Limitations on federal positions and resulting reliance
on contractors continues to be a serious problem. In-house
expertise and public confidence in Agency decisions cannot be
nurtured while amen of the scientific work is delegated to
contractors. While ethical standards exist, their emphasis is on
legal and regulatory constraints rather than on opportunities.
Similarly, QA is being developed for" laboratory procedures rather
than as a framework for Agency scientists to produce quality
products. Constraints on travel have a particularly devastating
effect on scientists, since exchange of scientific information and
the enhancement of the Agency's image are the two primary objectives
of participation at environmental conferences and professional
meetings.
COSTS i Converting much of the budget for the contract work to in-
house resources should have no effect on the budget. Establish a
travel budget of at least §15,000 per scientist.
BENEFITS: Decreased staff turnover and increased job satisfaction
throughout the Agency
MEASURES 0? SUCCESS i Increased public confidence in Agency
decisions, policies, and regulations and increased representation of
EPA scientists on national panels.
C.Z Career Ladders and FroaotioB/Xncentive/Revard Systems
WHATi Create r system *hat links grade assignments to the
contributions of the individual.
A traditional approach to position classification is no longer
responsive to the Agency's need for flexibility in creating career
ladders linked to organizational goals and individual achievement.
If we agree that "science" forms the backbone of this Agency,
scientists should be able to reach senior levels (through their
scientific" contributions and achievements) in the Agency, without
having to assume "Management" positions. Promotion systems should
provide the structure and criteria for advancement, but should not
liait then with artificial ceilings (glass or otherwise) .
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Aspects of the Merit Promotion Program should be re-eyamin-^ <
order to support the concept that jobs are created bvamn^ "
based upon programs tic needs, rather than £ploy..V
°f th' W- or
each Program, of f ice vd laboratory adopt thi
-
^""^ the «nnu.l appraisal cycle). Reward sstems
more competitive, innovative and I prestigiousf and ll™
routing "bean-oriented" and automated. New awlrd eatagerlM
nomination (including external nominations) and peer wvili
procedures nay be incorporated. Incentives and rewards may be
«K;??edithr°U?VeliOWShlpS' adv^or/ instructor assignments? min?!
J?! 5al8' 8Vt4.e"°f'the art labo«tory equipment, rotations or
time and support to pursue other USEPA aission-oriented endeavor^.
WHO: Task Force with cross sectio'n of USEPA scientists, Human
Resources experts and 1st t 2nd line supervisors (particular^
"Science" Managers - scientists managing scientists) «i«riy
TIME LINE: Develop Agency-wide policy for career paths, promotions
and incentive/reward systems to be implemented in FY95.
SS??ivRLSo "ana5ement may have reservations about implementing a
policy due to potential budgetary impacts. If "benchmarking" all of
the various scientific positions within the Agency is used in order
to develop the criteria, this could be a very cumbersome process and
it may end up falling under its own weight - well before a policy
statement could be developed. There may also be some hurdlei with
0PM to get over. Supervisors may feel that this only presents more
obstacles for them. They would need to receive extensive support
(training, incentives, time, etc.) to do this. It would also
require time and resource support to develop the policy and criteria
for this type of personnel management system.
COSTS: Development: $100,000, plus 6 FTEs for a vear-
lap lamentation: $75,000 for training agency-wide
* Dec""ed «ta" turnover; it's getting increasingly
difficult for the Agency to recruit and retain quality scientists.
More emphasis on rewards rather than punishments would improve
morale.* Increased job satisfaction and sense of career direction
SS?I!a?C? Perc«Ption» of "hidden" rules for advancement of
ISJ! 5*JT* ^hc A9«ncy. increased importance placed upon our
scientific workforce; increased pride. Improvement in the quality
Of science in USEPA.
21
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TEL: flug 27.93 9 = 23 No .001 P.23
KZASURZS 07 SUCCESS: An Agency-vide Policy and Criteria in place.
Adoption by all USEPA programs (HQ's and Regions) and labs.
Increased job satisfaction, pride and sense of career/direction -as
gained through regular employee surveys.
C.3 Employee-Empowered Scientific Recognition Committee
WHAT: Improve the way we reward scientists and technicians for
innovation, creativity and continuing scientific excellence by
iStablishing employee-empowered scientific Recognition Committees at
the Divisional level.
WHO: Create a "reinvention lab" to test this concept. This do-able
is modeled on an existing committee in ORD/HERL/DTD (contact person
Dr. Robert Kavlock) , but should be extended to other sectors
(Regions, HQ's) of USEPA
TIKE LIME: The model for this concept became operative vithin about
6 months of conception and is now in its second year. Briery, the
Division Director appoints a chairperson and, with ^the chair's help,
drafts a committee consisting of 2 technical staff, 2 principal
investigators (non-supervisory) and two supervisors n(tWelted II
members replaced each year). Award nominations are •olicij ted at
?east twice a year-anyone can submit a nomination at any time. The
is convened as nominations come in. It maxes
^
£eK£u£. but i.P consistent with «*"£«»»*
STS»^
groups within USEPA but each group would have to decide their own
criteria.
BXWMZRS- Inflexible interpretation of current USEPA award
Si?"?*! Resistance of managers to empower staff at all level, of
the organization.
COSTS: None: funds for these awards would come from the
established award pool (for on-the-spot and special acts).
BBKBTITB- Two years' experience with such a committee in DTD has
22
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competition and eliminates the suspicion of "supervisor's
favorites." 5) A potential long range goal would be to use this
approach to recognize and reward good science, and remove cash
awards associated with the official performance appraisal process.
Then, the performance review — unencumbered by the cloak of
financial intrigue — could be used productively to evaluate whether
goals have been aet and to set new goals and IDPs for the coming
year.
MEASURES OP SUCCESS: Annual review at DTD staff meeting to obtain
feedback on success of recognition program. Increased productivity
measured by established methods.
C.4 Training Tor Scientists
WHAT: Establish innovative career-development program to ensure
that scientists remain challenged and stimulated while fostering a
greater exchange and interaction between USEPA and the academic
research communities.
The Agency needs to develop a system that maximizes the human
potential of our scientists and thus the quality of science at
USEPA. The system should establish, in advance, a cohesive training
plan and budget for each position that is filled.
The prooram will require the establishment of a team of scientists
(working with Human Resources) to develop a step-by-step mapping of
advance career-development activities for each scientific position
which should include: (1) methods to ensure" active participation in
the rotation of USEPA scientists to outside science organizations to
Soaden the knowledge base of the individual, as well as the Agency;
(C financial support by the Agency for employee membership to
scientific professional organizations; (3) ^ablishment of an
Aaencv-wide long-term training program for scientists who are
invested in advanced training and remaining with the Agency; and
Sr^tablishment of agreements with local colleges and universities
to offer a wider variety of scientific courses at USEPA.
WHO: USEPA management
TIKE LIKEt Develop training plans for scientific positions by April
1994 and begin implementation by September 1994.
BARBXERSf Tight budget constraints exist, and USEPA lacks the
Support of eonVr... to provide the needed funding. Manager, may
Suspending funds on training scientists and opt for •P«nding it
on travel or oversight of extramural projects (especially non-
SSientifTc manner-) - Manager, may discourage training when it
involves allowing the employee to use government time and may make
it difficult for scientist, to participate in a rotational
assignments: Aggressive means of exchanging technical information
"?hTnt7rn;tio9n9al scientist., especially if it ^olves travel
funds or other resources, nay be viewed as only benefiting the
scientist, and not the manager or the Agency.
23
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LL : nag ^fi^O -3-^0 iNO.uoi
COSTSt Development: $200,000, plus 4 FTEs; Implementation: $0
rotational assignments; $50 fee for each member of professional
associations; $300-1000/training course.
BENETITSs Recognition of USEPA as a high-quality science Agency;
development of a strong base of top quality, stimulated scientists;
retention of quality scientists with institutional knowledge;
decrease the turnover rate of quality scientists; increase
productivity of quality scientific outputs through advanced
training; and, eliminate partial training of select scientists.
MEASURES O? SUCCESS: Gain public confidence; decrease turn-over
rate of quality scientists; increased morale; produce defensible
quality outputs; decrease in number of scientific challenges to the
Agency.
C.5 Recruitment of Scientists
WEATs Develop a short-term and long-term strategy for the
recruitment and retention of qualified in-house scientists,
engineers and technicians. ~
Such a strategy is crucial if USEPA is to achieve status and
credibility as a "Science Agency." Deficiencies in sustaining an
adequate scientific staff are increasingly evident as the Agency is
rapidly losing its institutional technical knowledge through
attrition. The strategy must sanction the recruitment of junior
scientists, engineers and technicians, who, under the mentorship of
senior scientists, will conduct in-house research and develop into
Agency experts.
Participation in the recruitment and hiring processes by peer-level
scientists from inside and outside the Agency should be a key
element of the recruitment policy. The strategy must also encourage
cooperation and coordination with external researchers. USEPA must
include in its long-term recruitment strategy a more sophisticated
plan for improving cultural diversity, including fostering
relationships with colleges and universities to attract top-notch
recruits. Another important part of the recruitment strategy should
include the placement (by recruitment or promotion from within) of
several world-class scientists (including current EPA experts) into
key policy and decision-Baking positions, as well as critical
research areas that are essential to reducing uncertainties in USEPA
decision-Baking.
WHO: Task force consisting of key Agency personnel and outside
scientists appointed by the Administrator
TIME LINE: Develop an implementation plan by the 2nd quarter of
1994
BARRIERS: Barriers to the successful implementation of this
recruitment strategy include the following: limited FTE ceiling,
liaited dollars for FTEs allocated by Congress, non-competitive
24
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salaries compared to industry, limited career tracks and inflexible
Human Resource Management guidelines for scientists, procurement and
ethics regulations that restrict communication between scientists,
limited travel budgets, limited and un-focused training program for
scientists across the Agency, recent policy to reduce 300* GS
14/15/SES positions, recent policy to suspend cash performance
awards for FY94 through FY98, very low morale of the current
technical staff.
COSTS: The political will to approach Congress and OMB with a
request for a significant increase in FTE ceiling. Part of the
argument should address switching R4D dollars for PRO dollars to pay
for FTE ceiling increase. This approach would not increase the
total dollars allocated to the Agency.
BENEFITSi The following benefits would be derived from the
implementation of this recruitment strategy: increased respect for
Agency decisions, increased respect for Agency scientists and
engineers, increased confidence in Agency data, recognition and
acceptance of USEPA as a science agency, increased morale and
productivity within the Agency technical workforce.
MEASURES OF SUCCESSt The ultimate measures of success would result
from environmental scientists around the world recognizing USEPA as
the source of expertise in environmental science and technology, the
primary training ground in environmental science and technology, a
reliable source of quality environmental data, a leader in
environmental methods and technology development, and a promulgates
of regulations with sound technical basis.
D. Communication and Coordination '
0.1 Prioritisation of X&tra-Agency Communication and
Coordination
WHATi Give special emphasis to communication and coordination of
scientific activities within USEPA.
Effective intra-Agency communication and coordination is essential
to achieve high-quality science products (research, regulations,
guidelines, policies and decisions). The scientific resources
throughout the Agency must be identified to facilitate direct and
productive interaction of scientists working on related issues. In
addition, readily available information on projects/activities
currently on-going within the Agency (Headquarters, Regions, ORD-
Laboratories) must also be identified and periodically updated.
Xdentific tion of resources and projects/activities will serve to
coordinate scientific efforts within the Agency.
Thus, it becomes essential that coordinators be designated in all
programs to foster communication among scientists and avoid
replicate efforts. Communication between risk managers and
scientists involved in risk assessments requires that risk managers
convey clearly what information they need from scientists, so that
25
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T c L • n u 3 ^ r . 3 o
•dentists can respond clearly and factually (including the
uncertainties in the risk assessment). Training of scientific
personnel in media communication should be made available (and in
some cases, mandatory) to allow proper identification of the needs
and level of communication required by the target audience. Non-
scientific personnel should be encouraged (and in some cases,
required) to receive scientific training as part of their career
development.
WHO: USEPA-vide task initiated by the Administrator and implemented
at each program, Region and ORD-Laboratory.
TIKE LIME: This -should be a continued effort supported by the
Agency. The first phase of this task (identification and
coordination of scientific resources and projects/programs) should
be in operation by Fall 1994.
BARRIERS: Major barriers in communication and/or coordination of
scientific efforts would be those imposed by statutory restrictions,
which would limit the amount and nature of the information that can
be shared. Although these are intrinsic and may not be easily
removed, the need for improved communication and coordination of
scientific efforts within the Agency should be recognized by the
Administrator, Assistant Administrators and other upper- and middle-
level managers as a vital key to achieve high-quality science.
COSTS:
a. Low Cost- Identify (through a survey) the scientific resources
within the Agency. Identify the components of the different
programs/projects in Headquarters, Regions and Laboratories.
Create a document, database or other form of transmission media
for disseminating the gathered information, with periodical
update of the information. This could build on the Scientific
Registry being piloted by the Sci/Tech Committee.
b. Medium to High Cost- Training of non-scientific personnel;
Training in risk communication; Training in communication skills.
Designation of intra-agency coordinators in FTE positions.
BENEFITS! The benefits of communication and coordination of
scientific activities within the Agency are significant. Replicate
•fforts can be avoided, which would result in savings in time and
costs. Improvement in communication and coordination within the
Agency (among scientists and between scientists and managers) will
improve the quality of science. This will have a direct effect in
the quality of the decisions, regulations, research and risk
assessments generated by the Agency. In turn, the Agency's
credibility by the public, the scientific community in other
agencies and academia, industry and Congress will improve. The
increased credibility of the USEPA as a high quality science agency
and a leader in all aspects of environmental science could result in
increased funding to further expand the Agency's capabilities.
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MEASURES O? SUCCESS: The success of an improved communication and
coordination system within the Agency can be measured by the gains
in the quality of science products generated by the Agency.
The ultimate measure of this success would by the recognition by
ethers (the scientific community, industry, other agencies and
organizations, Congress and the general public) that the USEPA is a
high quality science agency and the leader in all aspects of
environmental science. *
^
0.2 Zxchang* of Scientists (internally ft externally) For
Purposes of Zxcharigiag Science
WHAT: Increase scientific contact and openness within USEPA as veil
as with other government and private sector organizations.
The coordinated exchange of USEPA scientists within USEPA
laboratories, Headquarters, and the Regions, as well as among other
federal agencies, academia, and international organizations, will
nake its scientific and technical efforts more widely known. Such
an exchange program would ensure that USEPA scientists are
continually exposed to current knowledge and methodologies.
•
To accomplish this the Agency should promote and increase the number
of details and rotational opportunities within USEPA. USEPA should
require that every laboratory and program office, whether in Region
or in Headquarters, mandate that rotational assignments/details
outside of a scientists own immediate program take place at some
optimal level of their career. These rotational assignments should
last for a minimum of 30 days. Administrative and management
procedures should be checked to ensure that no barriers exist to
Inhibit these rotational/detail activities.
In promoting the exchange and sharing of science between USEPA and
other government and private sector organizations, the Agency should
implement the recommendation contained in Safeguarding the Future;
Credible Science. Credible Decisions.. The Quality of Scientists at
USEPA, Recommendation 3 (pp.31-32). The details for the
implementation of this recommendation would be left to the Agency to
determine.
WHOt USEPA-wide, coordinated by personnel offices in the Regions,
laboratories and Headquarter*.
TIKI LIME: Develop an implementation plan for the intra-Agency
rotational/detail assignments by the end of FY94. Develop an
implementation plan for the exchange of scientists between USEPA
and the outside scientific community by early FY95.
BARRIERSi Coordination with other programs to allow the optimal
exchanges will be complicated. Some may object to the disruption of
their staff. The rotations involving relocation may require special
attention, due to cost considerations. Some entrenched employees
may object to the mandatory nature of the rotations. Concerns may
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exist over the opening of USEPA offices to non-USEPA employees,
especially over Confidential Business Information (CBI).
COSTS: Costs will be minimal for internal rotations, with
relocation and per diem costs being the largest out-of-pocket
expense. Two (2) Billion dollars sight be set aside for the
external rotation program for the first year; that budget could be
altered as the success and size of the program is determined.
BENEFITS! Cross-program understanding; a more multi-media,
pragmatic workforce; greater future sharing of information as a
result of networking. All of these would help improve the quality
of science in the Agency.
XEA8URES OF SUCCESS: Improved sharing of information across
program; high number of rotations/details reflecting interest in
program; better relationship with other governmental and
private-sector organizations.
D.3 Communication and Coordination vith Other Federal
Agencies, state and Local Agencies, and International Organization
WHAT: Create frequent opportunities for USEPA scientists to be
exposed to current knowledge, data, and methodologies from other
agencies and organizations, as well as to communicate findings and
advice to them.
Among the federal agencies, USEPA is fifth-in the dollars spent on
environment research. The states have five times more scientists
monitoring the status of the environment than does USEPA. Many
international organizations (WHO, OECO, World Bank, Japan, United
Nations, etc.) look to USEPA for scientific advice.
Within USEPA, scientists are separated by organization (four
programs, ten regions, and the Office of Research and Development
(ORD)) and location (35+ laboratories facilities). State agencies
often cannot explain the science behind the regulations and
regulatory actions to the public. The public is willing to comply
if they could understand the rationale behind the Agency's
decisions. Communication of USEPA scientists with their
counterparts in international organizations, e.g., OECD, is crucial
to the USEPA efforts on guideline harmonization. The communication
to other agencies/organizations should be consistent, accurate, and
frequent to build credibility as a strong scientific agency.
USEPA should plan and co-host meetings and workshops on scientific
issues with other federal agencies which senior USEPA senior
management would be expected to attend. Scientists from across
USEPA would attend in numbers proportional to the other federal
agencies. Regions would host similar meetings for states and field
offices for federal agencies. USEPA should develop a focal point
for scientific expertise to ensure that we provide accurate,
current, consistent advice to international organizations.
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WHO: USEPA-vide task force appointed by the Administrator. The task
force vould include scientists from ORD, programs, and Regions.
TIKE LINil First meeting planned for February 1994 with full
implementation plan by October 1994.
BARRIERSi The greatest barrier vould be the budget and managers'
approval to travel. Travel dollars to attend these types of meetings
do not exist in the present budget. The present culture will not
invest the time and funds in this kind of long term investment.
There also would be resistance to the formation of another task
force.
COSTSs For four national meetings and ten regional meetings per
year - $60,000. Travel funds for these meetings - $500,000.
BENEFITSt Improved communication between USEPA scientists and
scientists in other federal, state, and international
agencies/organizations would result in more credible environmental
science, better compliance with our regulations, and reduction e?
wasted and duplicate efforts. -
MEASURES OP SUCCESSt Survey developed by the task force for USEPA
scientists, other federal agencies' scientists, and state
scientists, to be completed by February 1994. The same survey
instrument would be used again in February 1995 and February 1997.
D.4 Communication and Coordination vitb Academia and Industry
WRATs Develop Environmental Technology Re-invention Laboratories
based on collaborative efforts of the Agency with universities and
industry.
USEPA's environmental protection strategies are undergoing important
paradigm shifts. The most important include: risk-based priority
setting, pollution prevention as the preferred approach over
pollution control, and increased attention to reducing ecological
risk.
USEPA should encourage and legitimize the open collaboration of
Agency scientists with academia and industry in the development of
innovative approaches to pollution prevention and cleaner production
technology. Such creative and non-traditional efforts will help
ensure an American scientific, technological and industrial presence
'in the international marketplace. Open and unfettered communication
and coordination with industry, in particular, will serve as the key
to success.
VBOs The Administrator's Science Advisor, in collaboration with the
Office of Prevention, Pesticides and Toxic Substances (OPPTS) with
its links to industrial and agricultural chemistry and Design for
Environment Program (DfE), and the ORD Office of Science, Planning,
and Regulatory Evaluation (OSPRE) would serve as the Agency-broker
on communication and coordination for a FY94 pilot program. The
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TEL: flug 27.93 9=25 Nc.OOi r.5i
program would be conducted jointly with the National Science
Foundation's (NSF) Environmentally Benign Chemical Synthesis and
Processing Program and the NSF Industrial-University Cooperative
Research Center at the University of Washington's Center for Process
Analytical Chemistry. The industrial sector would be represented by
the Dow chemical - Perkin-Elmer Strategic Alliance Ventures Group
recently established to extend the practical use of advanced
analytical technology into applications of real-time industrial and
environmental monitoring.
«
TIKE LIMEs Fifteen months to produce a report to Administrator
Browner and Vice President Gore on the feasibility, limits and
opportunities of USEPA/NSF coordinating innovative Design for
Environment and Pollution Prevention programs with environmentally-
based advanced technology ventures in the private sector.
BARRIERSt Three types of barriers to success exist:
Historical and cultural reluctance of USEPA to aggressively,
openly, and effectively collaborate as equal partner with
industrial sector subject to Agency regulations, and with
technology-based firms who may benefit front close and
privileged Agency ties.
Znteragency turf battles where USEPA and other science agencies,
each protective of their own perceived sphere of influence and
control, will stifle coordination.
Intra-agency resistance between and among Program Offices and
ORO. Current USEPA measurement and monitoring programs are
predicated on pollution control with virtually no experience or
expertise in pollutant transformation processes. Reluctance of
Air, Water, Solid Waste and RCRA programs to adapt and adopt
Performance-based measurements as opposed to USEPA Approved
Methods-based measurements.
COSTSi Extramural investment modest — primarily to support
meetings and report development and production plus travel budget to
Dow, Perkin-Elmer facilities and to CPAC. Intramural resources
modest — senior scientists from Administrator, Program and ORD
Offices and Labs, plus travel budget to support staff.
BENEFITS< Effective and efficient communication and coordination of
pollution prevention activities between the Agency and the industry-
university communities will significantly leverage modest federal
resources with private sector investments. Creating a mutually
supportive culture between USEPA and industry supportive of national
environmental and economic goals will reap long-term economic
benefits.
MEASURES OF SUCCESS: The success of effective and efficient
communication and coordination of this effort may be measured in a
series of agreements between USEPA and industry to adopt specific
advanced analytical technology to replace outdated and costly Agency
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methods and procedures. The October 1994 report would clearly
identify quantifiable measures of savings, where appropriate! or the
generation of better data for decisionmaking and compliance at
comparable costs.
D.s Communication and Coordination with Congress, OK£, Kevs
Media, and the General Public
WHAT: Develop new and improved means to present its science-based
activities 'to lay audiences.
USZPA's greater emphasis on cross-media planning and scientific
•fforts will result in a more coherent and efficient effort by the
Agency to resolve complex environmental problems. This cross-media
emphasis will require enhanced cross-media budgeting. This presents
a serious communications challenge with respect to OMB and with the
various Congressional oversight and appropriations committees and
subcommittees. The issue of how the communication of USEPA's
research and science accomplishments affect the budget process is
critical to the financial health and well-being of the Agency's
science program and its scientists.
Specifically, USEPA need to take the following steps:
when presenting its programmatic and research projects to
OMB, reflect the cross-media perspective rather than the
perspective that fragments environmental protection into
different media
t
adopt a communication strategy that aggressively supports the
Agency budget — i.e., obtain and disseminate to the public
and affected industrial and agricultural sectors the best
possible scientific information and ensure the nation's
scientific expertise is enlisted in the service of USEPA's
mission
increase the number and quality of Congressional briefings —
offering Congress an open invitation to utilize USEPA
resources, as needed, to gain further information on topics
of interest
increase the number of its personnel/scientist* on loan to
Congress/White House
interact more positively with the news media on releasing
important environmental issues/decisions associated with the
Agency, emphasizing press releases that reflect high-quality
of science, convey it in a clear manner, .and 'contain
information that precludes conjecture and avoids negative
publicity
hold public forums on science for selected target audiences
in order to adequately present the information and address the
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TEi_:
audience's concerns as veil as enable the audience to provide
necessary feedback to USEPA scientists
serve as a leader in fostering environmental education for the
general public, taking advantage of community-based
organizations and placing special emphasis on educating and
informing the public on issues of exposure and risk analysis,
risk assessment and management, and risk communication
encourage public outreach by its scientists, emphasizing
environmental education, in grades X-12, as well as in
colleges and universities (especially schools with scarce
resources) — this outreach effort would also include a strong
focus on stimulating students to follow science and
engineering careers
The Agency should reexamine its present approach of using non-
technical staff versed in communications and trying to bring them up
to speed on the technical issues. A more effective approach would
be to employ individuals with strong technical backgrounds and train
them to be skilled in the effective use of communication and public
relations tools. There already are'many scientists at USEPA who
possess excellent communications skills. Their abilities should be
tapped to explain scientific principles as a complement to the
communications staff.
WHO: This should be a high-priority team effort on the part of the
Program Offices, ORD, the Office of Congressional and Legislative
Affairs (OCLA), and the Office of Communications and Public Affairs
(OCPA). The communication materials should be prepared in terms
non-USEPA scientists, Congress, and the public can understand.
TIME LINE: A Workgroup should be convened to develop a workplan and
schedule to meet the near-term and long-term objectives of
communicating with Congress, OMB, the news media, and the general
public. The workplan should be submitted to the Administrator by
February 1, 1994. The lead Offices would be OCLA and OCPA with
scientific staff detailed from ORD, OPPTS and other Program Offices.
BAWUERS: Historical roles of professional communicators versus
professional scientists, engineers, and technologists will make
implementation of come objectives problematic. Top management
support will be required if true change is to be accomplished.
«
COSTS: Significant intramural and extramural resources will b«
required over the long-tern. In the short-term, current staff may
be assigned to scope out the program and develop the workplan.
BENEFITS: The short- and long-term benefits to the Agency are
significant. Improved understanding of the Agency's scientific
basis for decisiorunaking by Congress and OMB is desirable in its own
right. The improvement of communication with the news media is
obviously in the Agency's own self interest. Communication in an
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•ffactive and meaningful manner with the general public is an Agency
obligation. * *
NEASUftzs OF SUCCESSi Short-terw measures of success may be measured
in numbers of events, i.e., briefings, articles, public meetinos
where USEPA science is presented and discussed. Longer-term
measures will require some normative assessment of the perception
positive and negative, by Congress, OMB, the news media and th4
public on the "quality of science and decis4onmaking" at USEPA
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REFERENCES
"A Global Marshall Plan: Developing and Sharing Appropriate
Technologies "garth In The Balance: Ecology and tn«\UBSS sg^lt
by A. Gore; Published by Plume, New York, 1993.—
"Aining Before We Shoot: The Quiet Revolution In Environmental
Policy"; Address by William K. Reilly, Administrator, U.S.EPA to The
National Press Club, Washington, D.C, September 26, 1990.
"Cabinet Fever,1* Government Executive, published by National Journal
Incorporate, Volume 25, Number 7, Washington, D.C., July 1993.
gpmffun.iea.tinq Risk to Senior EPA Policy Makerat A Focus Group study.
Produced by O.L. Bloom, D.M. Byrne and J.M. Andresen for the Office
of Air Quality Planning and Standards, U.S. Environmental Protection
Agency; March 1993.
Reducing Risk; Setting Priorities And Strateoiea For EnvirQnnmr«-«i
Protection. U.S. Environmental Protection Agency,
Science Advisory Board (A-101); SAB-EC-90-021, September 1990.
Safeguarding the Future! Credible Science. Credible Decisions.
Report of the Expert Panel on the Role of Science at EPA to
William K, Reilly, Administrator, U.S, Environmental Protection
Agency; EPA/600/9-91/050, March 1992.
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