Final Report
A Report to the Board from the
SAB Subcommittee on the
Mission and Functioning of the SAB,
Accepted by the SAB Executive Committee
on October 23, 1989
Printed on Recycled Paper

1.1	Reasons for the review		 1
1.2	The approach taken by the review			2
2.1	The formal mandate, charter, and apparatus			3
2.2	SAB's aiding-and-extending mission 		4
2.3	SAB's auditing-and-certifying mission 		 .	5
2.4	The foundations of SAB's authority	6
3.1	SAB's purview: Science for environmental protection	6
3.2	Consideration of science in context		7
3.3	Current advisory functions			8
4.1	Nomination, appointment, and reappointment	 10
4.2	Executive Committee nomination of new SAB members
and consultants 						 11
4.3	Recruitment and breadth of representation 		 12
4.4	Safeguards against conflicts-of-interest 		 . 13
5.1	Current array of committees and subcommittees 		16
5.2	Use of ad hoc subcommittees		18
5.3	Reorganizing to handle ecological issues better		19
5.4	Reorganizing to handle drinking water issues better		20
5.5	Intercommittee coordination		21
6.1 The Executive Committee's responsibilities 		 22

6.2	Orchestration of Board projects 			22
6.3	Transmittal of SAB reports 				23
6.4	Upgrading the Executive Committee's leadership role . . 			24
7.1	Relations with the Agency, in general 			25
7.2	Potentially-SAB-relevant EPA program and research offices ......	27
7.3	Advising EPA laboratories and regional offices 		28
7.4	Relations with other advisory bodies 				29
7.5. Relations with other advisory clients 			31
7.6 Openness and relations with the public		32
8.1	Setting priorities and the agenda			 .	33
8.2	Criteria for undertaking SAB studies 				35
8.3	Timing and timeliness 			36
9.1	Staffing 					38
9.2	The Board's responsibilities toward the staff				40
9.3	Staff Office operations		 . . 					41
9.4	Operating budget			 			42
10.1	Providing forums and pursuing outreach 			44
10.2	Advising on implementation and public communication		44
10.3	Helping the Agency be more anticipatory and strategic ........	46

Over recent years the need and demand for advisory service by the EPA Science
Advisory Board (SAB) has increased substantially, and the diversity of issues brought
before the Board has increased as well. This has strained the Board's capabilities, even
while it has raised challenging, important opportunities for stewardship.
In the spring of 1989 the SAB Executive Committee decided that a stocktaking was
desirable, and it requested that an ad hoc subcommittee conduct a broad review of the
mission and functioning of the Board. This report from the Subcommittee to the Board
presents findings and proposals that can be reacted to and implemented as the SAB and the
Agency wish.
The Subcommittee believes that the basic legislated mandate and the administrative
charter of the Board are appropriate and adequate. The Board has two principal missions:
an aiding-and-extending mission, and an auditing-and-certifying mission. Its overall
purview is science for environmental protection - that is, science, not policy; and science
not just for regulation, but for protection of the environment via the whole range of means
available to the EPA.
Currently the SAB performs the following functions: reviewing the quality and
relevance of particular regulatory science; reviewing generic regulatory-scientific
approaches; reviewing research programs; reviewing the technical bases of various applied
programs; advising on infrastructural and technical management issues; advising on
emergencies and other short-notice problems; and advising on broad, strategic matters.
The report suggests that the SAB would contribute even more if several other
functions were added or upgraded: providing scientific forums and pursuing outreach;
advising on aspects of implementation and communication; and helping the Agency
anticipate problems and act more strategically.
As to internal SAB improvements, the report recommends more active involvement
of the Board in nominating new Board members; recommends broadening of recruitment

and diversification of representation in Board membership; recommends some alterations in
SAB committee structure; and recommends heightened leadership by the SAB Executive
Committee in relating with the Agency and other organizations, in setting project priorities,
and in orchestrating the Board's activities.
As to external reach and relationships, the report recommends expansion of SAB
coverage of Agency programs; recommends more deliberate selection, planning, and timing
of advisory projects by both the Board and the Agency; recommends more active
coordination with other advisory bodies; and recommends more vigorous outreach to
various scientific communities and to the public.
As to workload and resources, the report recommends that the SAB staff support
and computer efficiency be improved and the budget increased to match the expectations,
demands, and opportunities of SAB advisory service. The Board's infrastructure needs to
be renewed.
Overall, the report makes a number of recommendations meant to improve the
SAB's ability to help the EPA anticipate environmental issues and act more strategically in
addressing them.

At the request of the EPA Science Advisory Board (SAB) Executive Committee an
ad hoc subcommittee has conducted a broad review of the mission and functioning of the
Board. This report from the Subcommittee to the Board presents the findings and
proposals so that they can be reacted to and implemented as the SAB and the Agency
The report is intended to stimulate discussion and improvement within SAB circles
(members, consultants, staff) and between the Board and the Agency, and to inform other
interested members of the government, scientific community, and public about the Board's
The review started with the assumption -- which was confirmed by the study — that
the Board basically is quite healthy and is contributing in crucial ways to the Agency's
work. Its purpose was to explore whether there may be ways for organizing and operating
even more constructively, extending the Board's reach, or being more anticipatory.
1.1 Reasons for the review. At least four concerns, which arose concurrently,
motivated this review.
First, the review was prompted by a desire to be sure the SAB is as well prepared
as it possibly can be to address the daunting environmental problems the world, and the
EPA, now are becoming engaged with -- such as the atmospheric and climate-change
threats, which are truly global, nearly intractable, and deeply interdisciplinary.
Second, the review was prompted by the need to be responsive to recent changes in
the emphases that the Administration and the Congress are pursuing -- such as giving more
attention to ecosystem issues, which in recent years have been relegated to secondary status
while human health concerns Have been attended to, and striving harder to prevent, not just
remediate, pollution.

Third, the review was prompted by a general interest on the part of the Board, after
several years of coping with a steadily increasing workload, to step back and examine how
well it is doing, recast some of its approaches, examine some complaints and proposals,
grasp opportunities, reconsider priorities, and strengthen the SAB infrastructure.
And fourth, the review was prompted by the desire to foster dialogue with the
Agency and develop a centerpiece report that might help mesh the Board's expectations
and working style with those of the Administration.
1.2 The approach taken by the review. Consonant with the Subcommittee's
initial conviction that the SAB is fundamentally solid, and respecting the dictum, "If it
ain't broke, don't fix it," this report strives to suggest possible upgradings that will
conserve and build upon the present strengths of the Board.
For these reasons, and to introduce less-familiar readers to the SAB, the report's
sections begin with brief commentaries on the current situation, then move to endorsement
of the status quo or proposals for change.
The report defers most staff-specific issues to Section 9. But it should be
appreciated that all SAB work is facilitated by the Board's professional and clerical staff,
who serve at EPA headquarters in Washington. The contributions of SAB members,
consultants, and staff are thoroughly integrated. The staff deserve substantial credit for the
Board's accomplishments.
In developing this report the Subcommittee surveyed the record (especially that of
the SAB's work in recent years), read critiques of the Board and analogous advisory
groups, interviewed numerous current and former SAB members and staff, sought the views
of current and former EPA officials, led several discussions with the SAB Executive
Committee, and in general solicited comments from a wide range of individuals and
external organizations. The Subcommittee is grateful to everyone who contributed to the

2.1 The formal mandate, charter, and apparatus. The EPA has tapped external
scientific advice since its beginning. When the Agency was founded in 1972, in part by
amalgamating environmental units from several Federal agencies, the merging units brought
along some of their advisory apparatuses. These began advising the new Agency on R&D
issues. By 1974, in order to secure more centralized, coordinated, and efficient advising,
most of the advisory groups were merged to form the Science Advisory Board. The
SAB's reach soon expanded beyond R&D matters to cover a variety of Agency scientific
The SAB became even more firmly established in 1978, under the Environmental
Research, Development, and Demonstration Act. This founding legislation stipulates that
the SAB provide "such scientific advice as may be requested by the Administrator, the
Committee on Environment and Public Works of the United States Senate, or the
Committees on Science and Technology, Interstate and Foreign Commerce, or Public
Works and Transportation of the House of Representatives." Biennially, as is called for by
the Federal Advisory Committee Act, the EPA Deputy Administrator revises and renews
the charter.
The SAB charter requires that the Board "consist of a body of independent scientists
and engineers of sufficient size and diversity to provide the range of expertise necessary to
assess the scientific and technical aspects of environmental issues." To avoid the potential
for conflict-of-interest, it directs that "no member of the Board shall be a full-time
employee of the Federal government." It requires that an Executive Committee lead the
Board. And, in accordance with provisions of the Clean Air Act, it authorizes the
continuing operation of a Clean Air Scientific Advisory Committee (stipulating some
particular professional representations on the Committee and outlining some advisory
obligations). Beyond that, the charter leaves the Board free to organize itself to fulfill its
At present the Board is composed of some 60 scientists and engineers, assigned to a
variety of committees. As a reservoir of supplementary expertise, a roster of over 200

formally appointed consultants is maintained on standby, available to be tapped without
signing-on delay. Upon assuming service, SAB members and consultants are appointed as
Special Government Employees, which means that they file financial-interest statements,
take other conflict-of-interest precautions, and become eligible for a standard government
per diem salary (which a few members decline to receive) and reimbursement of travel and
other expenses. A fully-dedicated professional staff at EPA headquarters supports the
The Board works extremely hard. Indications of this are that in FY 1989 the SAB
committees held 54 full meetings and conducted many teleconferences, the SAB Office
processed 612 travel authorizations, members and consultants logged 14,609 workdays of
compensable duty, and the Board published 38 reports (listed in the Appendix).
In rendering formal substantive advice, as a matter of principle the SAB reports
(with few exceptions) directly to the EPA Administrator; the Administrator's Office refers
the SAB advice however it chooses within the Agency. For administrative purposes such
as budget, staff personnel, and logistical support, the SAB operates as a "dotted line"
function of the Deputy Administrator's office.
The SAB cultivates an atmosphere of openness, and of course it complies with the
Federal Advisory Committee Act and related regulations.
There is little disagreement over the SAB's broad general mandate -- as the 1987
revision of the charter formulates it, "to provide advice to EPA's Administrator on the
scientific and technical aspects of environmental problems and issues." Rather, concerns
have to do with more specific functional objectives, how they might be better met, and
what resources of advisory expertise and logistical support are required to do those jobs
2.2 SAB's aiding-and-extending mission. The SAB assists the Agency in a
number of ways, as this report will describe. It helps shape research programs, critique the
factual rationales that undergird regulation, evaluate pollution control technologies,
anticipate new aspects of environmental problems, and respond to emergencies.

As it works back-and-forth between EPA's top management (where science is
spottily represented) and operational EPA units, the Board helps forge science-related links
between the Administrator and the program offices, laboratories, and regional offices. It
helps ensure that the input the Administrator gets from Agency scientists is reliable.
Throughout, the SAB champions the application of the soundest science available.
Also, the Board reaches out in the interest of the Agency, helping solicit extensive
and diverse technical input, providing informal liaison with many other organizations, and
conveying some of EPA's messages. In acting as a continual open forum (including paper-
flow forum) on the scientific and technical aspects of the EPA's work, the SAB serves as
a nexus for judgment-gathering. This provides the EPA Administrator (and thereby also
other Executive Branch officers, the Congress, and the nation) with broad input and
"calibration." At the same time it provides a variety of concerned parties outside the EPA
with scientific windows onto the Agency, through which information can be passed in both
directions. The SAB windows are available both to those whose views the SAB actively
solicits, such as Board consultants, and to others in the public who take initiative to be
informed and involved.
2.3 SAB's auditing-and-certifying mission. Although it usually is taken as
granted, one central mission of the SAB is not quite explicitly conveyed by the formal
charter: SAB review of the scientific aspects of EPA work is widely relied upon as an
auditing, a dispassionate, objective critiquing of quality and relevance, for both the
Agency's benefit and the nation's.
SAB approval of the scientific basis of a plan, program, or scientific judgment is an
endorsement, a certification, in effect representing (if the Board does its job right) the
state-of-art judgment of the larger scientific community.
SAB disapproval or skepticism is at minimum a signal of possible inadequacy.
Sometimes, because of timing or resource or legal constraints, the Agency simply is unable
to develop or apply the best science conceivable. Sometimes political factors trump
science. And sometimes, even after much discussion, the Agency and the Board just end
up viewing matters differently.

Formal SAB approval lends authority to an EPA position. Formal SAB disapproval
puts a burden on the Agency to publicly justify its differing rationale. The Congress,
regulated enterprises, the newsmedia, and others widely hold SAB's reviews in this regard.
Thus, the Board's "advising" has much broader ramifications than merely "giving
suggestions to the EPA."
2.4 The foundations of SAB's authority. Although the SAB's existence is
mandated by Federal legislation, and the Board is actively consulted by the EPA, ultimately
the SAB's social trustworthiness and authority derive from two interrelated sources: the
Board's grounding in the larger scientific and technical communities, and its reputation for
acting with integrity. The Board must stay in touch and in tune with state-of-art science. .
SAB's leaders must be environmental statesmen who have won scientific recognition and
command the respect of other scientific leaders. SAB's specialists must be experts who
are highly regarded by their peers. And in all of its advising, the Board must "call it as it
sees it" scientifically. Any erosion in these regards would undermine the SAB's credibility
and weaken its potential as a resource for the EPA and society.
3.1 SAB's purview: Science for environmental protection. The SAB operates on
the conviction that its mandate is to assist the EPA in marshaling the very best science
available for protection of the environment, and to help integrate scientific considerations
into Agency strategies and decisions.
Two implications follow from this construal. The first is that the Board's obligation
is to focus on scientific and technical aspects of issues, and refrain from making public
policy judgments ~ it is the Science Advisory Board. Nonetheless, because the SAB is a
group of human beings evaluating uncertain science for application to knotty issues in the
very real world, the science-policy separatism cannot be absolute. The environmental-
science, engineering, and public-health professions have built long and honorable traditions
of wrestling with pragmatic judgments. Factoring out the scientific aspects of complex
' hybrid societal problems for advisory scrutiny is an important self-discipline the Board

must maintain, and it is a consideration that the Board asks the Agency to respect and help
The second implication is that the SAB does not focus solely on science for
regulation. Like the EPA itself, the Board believes regulation to be only one of many
instruments - along with monitoring, research, technology improvement, training, education,
lifestyle change, economic incentives, and other approaches - for protecting the
environment. Certainly one of the Board's most important functions is reviewing the
specific technical bases for particular major regulatory decisions, and this should continue.
But as this report will illustrate, quality-assurance of regulatory science is far from being
SAB's only task.
3.2 Consideration of science in context. The Board deals with science;
nevertheless, it is obliged to be sensitive to the social and policy contexts within which the
science will be developed and put to use. The SAB cannot judge what degree of precision
and accuracy should be required of any scientific analysis without taking into account at
least a general sense of what environmental (not just financial) "stakes" hinge on that
analysis -- the higher the stakes, the more important it should be to reduce the uncertainty
(about the problem, about proposed solutions). Nor can the SAB advise on the desirability
of waiting for more-certain science to come in, as opposed to going ahead and taking
protective action, unless it knows what is at stake; major threats may demand that the
EPA act without waiting for more definitive science. The SAB cannot evaluate the
effectiveness of research programs in isolation, without considering the larger scheme of
the EPA and other organizations' work. The SAB cannot assess environmental
technologies except in the context of real-world application. The SAB cannot review
research plans without exercising informed respect for research-budget constraints. Context
and relevance must be fully considered.
To the extent feasible, consistent with sound science, the SAB—EPA organizational
arrangements and operating dynamics must be oriented to the Agency's complexion and
agenda as these have been mandated by Congress and are being administered currently.
This holds structural implications (for example, the Agency has a highly specialized Office
of Radiation Programs, and the SAB matches this with a counterpart Radiation Advisory

Committee). It also holds operational implications (in advising the EPA Office of Drinking
Water, the SAB Drinking Water Committee naturally must respect the guidance of the Safe
Drinking Water Act). In the long-run, whether slightly "ahead of or slightly "behind," the
SAB must evolve basically apace with the Agency.
3.3 Current advisory functions. Over the years the SAB has provided the
following variety of services (the taxonomy isn't important):
Reviewing quality and relevance of particular regulatory science
-- Reviewing scientific information being used or proposed as the
basis for regulatory decisions (such as the criteria documents
that underpin the National Ambient Air Quality Standards);
-	Reviewing targeted regulatory-support research programs and plans
(such as surface-water monitoring protocols);
Reviewing generic regulatory-scientific approaches
-- Reviewing generic guidelines or protocols governing the use of
scientific information in regulatory decisionmaking (such as the
risk-assessment guidelines);
-	Critiquing analytic methodologies (such as mathematical modelling
approaches used widely through Agency programs);
Reviewing research programs
-	Reviewing and advising on medium-term R&D plans, programs, -
' and needs of EPA laboratory and grant programs (such as the
draft Office of Research and Development Pollution Prevention
Research Plan Report to Congress);
-- Reviewing and advising on EPA laboratories' capabilities, plans,
and research-in-progress (such as the Health Effects Research.
Laboratory's neurotoxicology research program);
Reviewing the technical bases of various applied programs
Evaluating environmental engineering practices (such as drinking-

water filtration and. disinfection technologies);
—	Assisting with remediation (indoor-radon mitigation) and
emergency preparedness programs (development of the acute-
toxic chemicals list under Superfund);
Advising on infrastructural and technical management issues
—	Reviewing Agency scientific personnel recruitment, career
advancement, research publication, and other infrastructural
— Advising on institutional issues (such as the organization of the
EPA laboratories system, or the need for a national .
Environmental Research Institute);
Advising on emergency and other short-notice problems
—	Critiquing contemplated responses to emergencies (such as the
pragmatics and research design of proposed bioremediation
of the Prince William Sound oilspill);
Advising on broad, strategic matters
—	Reviewing EPA's R&D program in broad scope (such as the
overall Office of Research and Development program plans
and budget);
-- Surveying problem areas the Agency hasn't at the time, in the
judgment of the Board, fully come to grips with in research or
regulation (as with municipal waste incineration in 1987-88);
—	Advising on — and helping anticipate ~ broad, strategic Agency
concerns and organizational preparedness for addressing them
(as the "Future Risk" study did).
More will be said about additional functional possibilities later. For the moment it
is important to keep the diversity of these advisory tasks in mind as the organizational
apparatus is reviewed.

4.1 Nomination, appointment, and reappointment. Nominations for SAB
membership are submitted from a variety of sources, including the SAB itself. Periodically
invitations to nominate are printed in the Federal Register, and the Agency repeatedly
makes it known that it will entertain nominations from the public.
Formally, SAB members are selected and appointed by the Deputy Administrator in
consultation with the Staff Director, who conveys the Board's preferences as to types of
expertise to be recruited, and names specific nominees. At present, Board members are
appointed for terms varying from one to four years,- staggered. As Section 4.4 will
describe, upon accepting the Deputy Administrator's invitation to serve, appointees must
comply with a set of conflict-of-interest rules and guidelines.
SAB consultants are appointed by the SAB Staff Director to one-year terms,
renewable. They must conform to the same conflict-of-interest rules as members. A
highly-qualified but specialized expert may serve more effectively as a consultant for one
project, rather than as a member, since members are expected to work fairly broadly. (One
difference between SAB members and consultants is that consultants are not empowered to
vote, formally at least, on issues.) To an extent, the SAB consultant pool serves as a
"farm team," from which especially productive contributors become identified and
nominated for SAB membership; obviously, promising Board candidates become identified
via other avenues as well. Also it serves as a mechanism for continuing to make available
the services of former members who have rotated off the Board.
Recommendation on terms of service. The variance in lengths of appointment strikes
this Subcommittee as unnecessarily irregular. The Board, and the Deputy Administrator
should examine the desirability of appointing, all members to two-year terms, renewable
twice, with a hiatus of at least two years required before the member becomes re-eligible for
further reappointment. Terms of service for committee chairs, for which cumulated SAB
experience is important, should be treated exceptionally (such as by waiving-the break-in-
service requirement).

4.2 Executive Committee nomination of new SAB members and consultants.
The SAB is counted on to nominate new Board members and consultants. It has always
done this, and its suggestions seem generally to have been deferred to. But the process
has been casual, has mostly been conducted outside of meetings, and seems to have heavily
reflected the SAB staffs preferences.
Operationally, the SAB Staff Director is the nomination locus: he consults as to
talent needs and recommendations with his Executive Secretaries, the committee chairs, and
the Chairman of the Board; he reviews the suggestions submitted to the Administrator by
EPA officers and external sources; then he discusses his findings with the EPA Deputy
Administrator, who formally issues invitations to serve.
The SAB staff, justifiably, are anxious that current members not simply perpetuate
the Board with their own kind, and are concerned to develop committee teams that are
compatible and efficient. Board members, just as justifiably, believe that the SAB staff
don't have sufficient experience, seniority, and reach in the nation's scientific communities
to be able to make the best selections. By dint of good judgments, the process has worked
satisfactorily; the current Board is rich in talents. But rarely in recent years has the
Executive Committee, as a committee in session, discussed exactly what new talents need
to be enlisted to the Board, or discussed specific possible nominations and their potential
impact on Board breadth, depth, and balance.
If the Board truly is to involve ~ and be viewed by the public as involving - the
most capable and representative leaders of the nation's scientific communities, nomination
should be made into a more regular Board process, coordinated by and participated in by
the SAB staff.
Recommendation on Executive Committee nomination of SAB candidates. The EC
should systematically solicit suggestions from the committees, survey the capabilities needed
for handling upcoming issues, discuss particular talents, consider SAB breadth and balance,
and nominate candidates for SAB service to the Administrator. (To encourage candid
discussion, these would be among the few occasions on which it is proprietous to close the
meetings to public observers.)

4.3 Recruitment and breadth of representation. Are all the necessary disciplines
and skills represented on the Board? How about balance of representation by women,
members of minority groups, and various social and political institutions?
The Board roster is diverse. A wide variety of technical disciplines are represented.
Many members come from academia, some come from national laboratories, some from
consulting firms, some from nonprofit thinktanks, some from industry, a few from state
government agencies, and a few from environmental activist groups.
One finding is clear. Representation by women and members of minority groups is
widely recognized (including by the Executive Committee) to be inadequate. Past
occasional efforts to rectify this haven't accomplished much.
Less clear is what improvements should be made in seeking to broaden
representation from various social and political institutions (such as environmental activist
groups and industry). SAB members are expected to represent themselves as scientists, and
not represent their institutions or geographic regions. But because a wide technical
experience base is desirable, and because perspective biases can never be totally eliminated
(engineers insist on quantitation, ecologists from the Chesapeake Basin tend to care a lot
about estuaries), the Board always has sought diverse membership. This should continue.
At least as important as balancing institutional backgrounds is balancing technical styles of
approach: modellers as against measurers, rodent-assayers as against epidemiologists.
Several commentors urge that the SAB involve more social scientists (such as
economists and decision theorists), communication experts, and environmental lawyers. A
few experts with social-science backgrounds, mainly in economics and operations research,
currently serve ably on the Board. SAB economists and economist-engineers regularly
-advise on.cost-benefit,analyses the.Agency performs in implementing the Clean Air Act,
and on economic considerations that arise in drinking water and other areas. Section 10.2
of this report outlines several possible expansions of SAB's role that would depend heavily
on social-science talents, which would have to be recruited. Almost certainly the most
helpful social scientists (or lawyers) for the Board are those who have broad interests and
environmental-science experience.

All of these personnel issues need to be deliberated over by the SAB committees,
and any shortcomings rectified. Recruitment should itself be made a project.
Recommendation on SAB recruitment. The Executive Committee should establish an
ad hoc Membership Nomination Subcommittee to work with the standing SAB committees to
identify and nominate a diverse roster of the experts required for the Board, making special
effort to recruit well-qualified women and minority scientists. Also this Nomination
Subcommittee should attend to the balance of representation from different institutional and
technical points-of-view.
In its recruiting -- which should be treated as a project, with progress reports to the
Executive Committee ~ this Subcommittee should review the findings and network of the
national Task Force on Women, Minorities, and the Handicapped in Science and
Technology; actively solicit nominations from relevant committees of such organizations as
the American Association for the Advancement of Science, American Chemical Society,
Society of Toxicology, engineering societies, ecological associations, and other professional
bodies; review the rosters of the National Academy of Sciences complex; and scout the
talents in state agencies and laboratories.
Because the Board can only nominate candidates, for selection and appointment by
the Deputy Administrator, the Board must work consultatively with the Agency leadership
to pursue this broadened recruitment.
If the initial (say, two-year) ad hoc project makes progress, the Executive
Committee might well convert the Membership Nomination Subcommittee into a permanent
subcommittee. Breadth of representation on the Board - with no compromise in
competence ~ would remain one of the Subcommittee's primary concerns.
4.4 Safeguards against conflicts-of-interest. Currently several conflict-of-interest
issues are being sorted out by the Agency and the SAB Office. This report can only
mention the basic considerations.

To the SAB, two overlapping conflict-of-interest concerns are central. The first is
ensuring the integrity of scientific advice rendered -- making sure that SAB members' and
consultants' personal biases and interests do not unduly influence the agenda, substance, or
style of the Board's advisory work. The second is ensuring that in participating in,SAB
activities, members and consultants not be in a position to influence matters that redound
to their personal financial interest, or that of their institutions.
Because public credibility is so crucial for the Board, both actual and possible
appearances of conflict-of-interest must be safeguarded against.
The legal background-is that SAB members and consultants serve as Special
Government Employees (SGEs), a category of part-time Federal service. Under the Federal
Advisory Committee Act all SAB members and consultants are required, upon appointment,
to file an official Statement of Employment and Financial Interests. This Statement is
examined by the SAB Staff Director, referred to EPA counsel if there is any indication that
legal judgment or advice might be desirable, held in confidential Agency files, and updated
annually. Confidentiality of personal financial records is important to SAB members and
consultants, and they ask to continue to be assured of this confidentiality and informed of
measures taken to ensure it. Under other Federal conflict-of-interest laws, SAB members
and consultants must also submit statements of corporate directorships and other relevant
affiliations. EPA Ethics Officials (in the Office of the General Counsel) advise SAB
members and consultants on their conflict-of-interest responsibilities and potential liability
The SGE status applies some restrictions on SAB members and consultants, in part
having to do with representing parties "on particular matters" (such as regulatory petitions)
before courts or Federal agencies, both during tHe term of SAB service and afterward.
Right now the Agency is reviewing the legal interpretation of these restrictions. They are
a source of considerable "apprehension for SAB members and consultants -1 and for other
scientists who might be future candidates for SAB service - who are "employed by, or Who
serve as consultants to, regulated enterprises.

This report, throughout, discusses a number of policies and procedures that help
ensure SAB openness, diversity, and balance. The Board itself expects that members
consistently will: (a) reveal their technical prejudices on issues, and any pertinent policy
biases; (b) disclose any possibility of financial interest on their part or the part of their
associates or institutions; and (c) absent themselves from deliberations where a possibility
of conflict-of-interest exists.
Advising on EPA research-grant programs is an area of sensitivity for SAB
reviewers, since SAB experts potentially might have an interest in the grant issues being
reviewed, but these judgments in the past seem to have been handled responsibly.
Upon disclosure to EPA counsel of a potential for conflict of interest, a member or
consultant may be granted a waiver if the counsel determines that the integrity of advising
is unlikely to be affected. Issuance of waivers becomes a matter of public record.
Finding on conflict-of-interest safeguards. To this Subcommittee, and surely to the
Board, the paramount objective is that the SAB be in position to render the most insightful,
broadly experienced, pragmatic scientific advice possible. In this light, the current conflict-
of-interest precautions -- if fully observed - seem entirely adequate.
The Subcommittee hopes that overly legalistic conflict-of-interest strictures will not
encumber the Board's service or discourage able scientists from contributing to the work of
the ,Board. Openness, a wide diversity of viewpoints, and candid, vigorous deliberations in
the high tradition of science, are the keys to rendering the soundest environmental advice.
The essential working units of the Board are its committees. Although all of the
committees are productive, recently a variety of questions have arisen as to whether the
current committee structure "covers the ground" (which, of course, is enormous, diverse,
and difficult) in the most effective and efficient way possible.

Is the present-array of committees that make up the Board the most appropriate?
Are any important substantive areas neglected? Are the committees structured and tasked
in the most effective way to meet the Agency's needs? . Is the heavy use of ad hoc
committees appropriate?
5.1 Current array of committees and subcommittees. At present the Board
comprises the Executive Committee (EC), eight standing committees, and a variety of
standing and ad hoc subcommittees. The EC, comprising the chairs of the standing
committees and several members-at-large, directs the activities of the SAB. The chair of
the SAB chairs the EC.
The full complement of SAB units (with their names rearranged to emphasize
topical subjects) includes:
Executive Committee (EC)
Dioxins, Ad Hoc Subcommittee on
Global Climate Stabilization, Ad Hoc Subcommittee on
Lead Issues, Ad Hoc Subcommittee on
Mathematical Models, Ad Hoc Subcommittee on
ORD Advancement Criteria, Ad Hoc Subcommittee on
Scientific and Technological Achievement Awards, Standing
Subcommittee on
Products of Incomplete Combustion (PICs) in Hazardous Waste
Incineration, Ad Hoc Subcommittee on
Relative Risk Reduction Strategies, Ad Hoc Subcommittee on
[Revisions of Risk Assessment Guidelines, various ad hoc
subcommittees to review (with the lead assigned to standing
committees in some cases)]
Environmental Health Committee (EHC)
Halogenated Organic Solvents, Standing Subcommittee on
Metals, Standing Subcommittee on
Environmental Effects, Transport, and Fate Committee (EETFC)
Long-Range Ecological Research Needs, Standing Subcommittee on
Sediment Criteria, Ad Hoc Subcommittee on
Alaska Oil Spill Cleanup, Ad Hoc Subcommittee on
Clean Air Scientific Advisory Committee (CASAC)
Ozone/Forest Effects, Ad Hoc Subcommittee on
Visibility, Ad Hoc Subcommittee on
Drinking Water Committee (DWC)

Indoor Air Quality/ Total Human Exposure Committee (IAQ/THEC)
Environmental Tobacco Smoke Risk Assessment, Ad Hoc
Subcommittee on
Environmental Engineering Committee (EEC)
Municipal Waste Combustion Ash, Ad Hoc Subcommittee on
Agency's Report to Congress on Pollution Prevention, Ad Hoc
Subcommittee on
Saturated Zone Model, Ad Hoc Subcommittee on
Incineration of Municipal Sludge, Ad Hoc Subcommittee on
Toxics Treatability and Toxicity Reduction, Ad Hoc Subcommittee on
Radiation Advisory Committee (RAC)
Radiation Dose-Risk, Ad Hoc Subcommittee on
Radiation Measurements, Ad Hoc Subcommittee on
Radiation Sources and Transport, Ad Hoc Subcommittee on
Research Strategies Advisory Committee (RSAC)
ORD Budget, Standing Subcommittee on
ORD Manpower Skills Mix, Ad Hoc Subcommittee on.
The array of committees is somewhat matrix-like: some committees have to do
with particular environmental media (Clean Air Scientific Advisory Committee); some with
effects (Environmental Health Committee); some with modes of hazard (Radiation
Advisory Committee); and some with disciplinary or remedial approaches (Environmental
Engineering Committee). Each of the committees has been established, and has evolved,
for particular historical reasons.
Three of the SAB committees -- the Clean Air Scientific Advisory Committee, the
Drinking Water Committee, and the Indoor Air Quality Advisory Committee ~ fulfill
(separate) legislated requirements that EPA secure external advisory input in these areas.
The statutes specify some duties; for instance, the Radon Gas and Indoor Air Quality
Research Act of 1986 requires that the Indoor Air Quality Committee review the Indoor
Air Quality Implementation Plans that the EPA prepares for the Congress. Although not
all of these committees are obliged to be made affiliates of the SAB, all serve effectively
and in an integrated way within the Board structure.
Finding on committee structure. With the exception of the ecological and drinking
water areas (being attended to, as discussed below), the Subcommittee believes the current

stable of committees generally is adequate. The committee structure matches the Agency's
complex organization fairly well. And, especially by employing ad hoc subcommittees, the
SAB is able to put together appropriate panels on issues coming up for attention.
There are virtues in basically preserving (or at least not scrambling) the current
committees, which have developed internal coherence and good working relations with the
EPA offices and other organizations in their areas. If, in the future, the SAB finds itself
advising much more actively in some large problem domain, such as atmospheric and
climate-change issues, the charter leaves the Board free to establish new committees or
subcommittees as it wishes.
5.2 Use of ad hoc subcommittees. Often, as the above list of committees shows,
in order to address a problem that is novel or that cuts across the standing committees'
interests, the SAB sets up an ad hoc subcommittee for the task, to be disbanded when the
job is completed. Usually the ad hoc group includes representatives from the relevant
standing committees and other experts as needed. Some observers find too much reliance
on ad hoc subcommittees, especially those set up to report only to the Executive
Committee; others find this no problem.
Finding and recommendation on ad hoc subcommittees. For many purposes ad hoc
subcommittees are a flexible way to organize, and they generally work satisfactorily. But ad
hoc groups should be set up only when the standing committees and subcommittees cannot
do the job at hand, and firm lead responsibility for ad hoc efforts should be assigned to
standing committees whenever possible. The intention should be to respect and preserve the
standing committees' functions, and to keep ad hoc efforts firmly integrated with the work of
the standing committees.
Incidentally, the Board recently decided that from now on, research-in-progress
reviews - some of which in the past have been conducted by very ad hoc groups, perhaps
reporting loosely to the Executive Committee — will be conducted by the appropriate
standing committees (or ad hoc subcommittees under their auspices).

5.3 Reorganizing to handle ecological issues better. Increasingly the Board has
become aware that neither it nor the Agency are as well prepared to address ecological
problems as they should be. The Board's 1988 report, Future Risk, called attention to the
shortcoming, as did statements from the affiliated Long-range Ecological Research Needs
Committee. The Administrator has announced strong intentions to upgrade the Agency's
emphasis on ecological problems, and has begun to implement those intentions.
Confronting this review was the organizational puzzle of how to accommodate these
three intersecting structure-and-mandate changes: (a) establish an ecological committee, to
broaden the Board's coverage of this whole area; (b) rework the Environmental Effects,
Transport, and Fate Committee (EETFC), to accommodate to the establishment of the
ecological committee and retune the Board's work on the movement and alterations of
media and pollutants; and (c) mesh these changes with the work of the Environmental
Engineering Committee (EEC), which, among a variety of other matters, pursues many
issues that can be viewed as having to do with transport-and-fate.
The Subcommittee conducted extensive discussions of these matters with all of the
concerned parties within the Board, and believes that the following recommendation
embodies the SAB consensus.
Recommendation on reorganizing to handle ecological issues better. The Board
should: (a) establish an Ecological Processes and Effects Committee (EPEC) with a very
broad mandate, having special interest in the effects of contaminants on ecological systems;
(b) convert the present Environmental Effects, Transport, and Fate Committee into an
Environmental Transport and Fate Subcommittee of the new EPEC; and (c) charge the
Environmental Engineering Committee with continuing to analyze transport and fate
phenomena that are associated with engineered sources or processes (such as mining
operations and waste-handling).
The new Ecological Processes and Effects Committee would, for example, review
the Agency's core ecological research program, review the ecological risk-assessment
guidelines the EPA is now developing, and work on issues having to do with specific
ecosystems (such as wetlands and estuaries).

The Environmental Transport and Fate Subcommittee would address such problems
as movement and alteration of air, waters, soils, and other media, and contaminants or
biota in those media, relating to ecosystem health and stability. It would analyze some
exposure issues. And it would review transport-arid-transformation monitoring programs.
Merging ecological-milieu and ecosystem-effects studies within the EPEC will help
integrate these considerations.
On some issues, such as combustion processes, the EEC might handle the pollution
source-release issues, the EEC and the Transport and Fate group jointly the movement from
the source out to ecosystem exposure, and the EPEC or a subcommittee the effects on
exposed ecosystems (while the Environmental Health Committee addresses any human
health aspects).
These proposals have been discussed extensively by SAB leaders in these areas as
this review has proceeded, and the Executive Committee recently approved the changes, in
principle. The EC should task an interim steering committee with finalizing the
committees' mission statements, and making recommendations to the EC on subcommittee
structure and on reassignment and augmentation of committee memberships. The next
phase of work in this arena should be very engaging.
5.4 Reorganizing to handle drinking water issues better. During the course of
the present review a strong plea was made by the Drinking Water Subcommittee of the
Environmental Health Committee that it be granted independence and converted into a
standing committee. The argument was that the drinking water enterprise is very large and
active (for both EPA and SAB) and will remain demanding for the foreseeable future, and
that the workload thus justifies full committee status. And further, although drinking water
issues are driven by health concerns, quite a few hinge on technical complexities of
groundwater protection, filtration, disinfection, distribution, water-quality analysis and
monitoring, and cost-benefit analysis, that just are not the province of health experts; so
interposing the EHC between the DW group and the Executive Committee doesn't make

The Executive Committee was persuaded by the merits of the proposal, and has
authorized the changes. Thus in the fall of 1989 the Drinking Water Committee (DWC)
became a standing full committee, and its chair a member of the EC. On health issues the
DWC is committed to coordinating with the EHC, and on engineering, with the EEC.
These committees should consider coordinating by making a few dual-committee
5.5 Intercommittee coordination. The SAB committees in general communicate
and coordinate their activities well. Given the intrinsic complexity of environmental
problems, it is not surprising that committees' "jurisdictions" intersect. But turf jealousies
are not very pronounced. Committees often undertake joint efforts, usually by spawning
hybrid ad hoc subcommittees to do the jobs. Because it includes the chairs of all of the
standing committees, the Executive Committee plays a prime role in sorting out issues of
committee intersection. The committees' Executive Secretaries also play this role, and they
have been pursuing it more vigorously recently. The monthly newsletter, "Happenings at
the SAB," very effectively helps communicate.
Recommendations on intercommittee coordination.
(a)	All committees should make continual efforts to be sure that they are aware of
other committees' work, and to apprise other committees of upcoming activities.
(b)	Where committees find themselves routinely intersecting, they should consider
designating liaisons, perhaps even appointing a few members to two committees
concurrently. If they find themselves overlapping redundantly, they should review the
organizational structure and territorial boundaries.
(c)	The Board should consider holding an SAB Annual Meeting at which all of the
committees would first conduct their business separately, then meet in various combinations
and in plenary session. With proper scheduling and planning, this could be at least as
efficient as the usual separate committee meetings, and could offer bonus opportunities for
coordination, planning, and collegial exchange. Also it could provide a very effective forum
for discussions with top EPA officials and with leaders of a variety of external

The Executive Committee, led by the chair of the SAB, comprises the chairs of the
eight standing committees and several members-at-large (who have tended to be generalists,
of no set number). Also, the chairs of the Clean Air Scientific Advisory Committee
(CASAC) and the Federal Insecticide, Fungicide, and Rodenticide Act Science Advisory
Panel (FEFRA SAP) sit on the EC, ex officio. The EC "runs" the Board.
Is the Executive Committee the right size and appropriately constituted'/ is it
performing well? Can it do more or better?
6.1	The Executive Committee's responsibilities. In general the EC is constituted
properly. However, the complex environmental issues that are now arising present severe
challenges to the EC's planning and leadership. On several aspects of the SAB's
functioning (to be-described), the EC must strive to work more robustly.
Recommendation on Executive Committee responsibilities. The Executive Committee
should consider its principal tasks to be:
-	"Scanning the environmental horizon, " sorting out priorities, and setting the broad
SAB agenda;
-- Representing the Board to the Administrator, the Assistant Administrators, and the
Lab Directors;
-- Conveying high-level Agency concerns to the SAB;
-- Searching out and nominating candidates for SAB service;
-- Outlining and chartering the committees' review and advisory tasks;
-	Coordinating the work of the various committees;
-- Receiving advisory reports from the committees, vetting 'them, and endorsing and
transmitting them to the Administrator (CASAC excepted); and
-- Representing the Board to the larger scientific and technical communities, and
• incorporating their input.
6.2	Orchestration of Board projects. As the environmental issues the Board
confronts become ever more trans-media, trans-disciplinary, and therefore trans-committee,

and as the Board's "reach" through the Agency expands, the EC must more dynamically
orchestrate the working of the SAB committees.
Recommendations on EC shaping and assigning of committee tasks.
(a)	On all major projects, whether initiated by the committees or by the EC or by
other sources, the EC should, to whatever extent is appropriate, debate the involvement of
committees, the scope of the issues to be investigated, the general approaches to be taken,
the Agency context surrounding the projects, and how the projects fit into the environmental
"big picture."
(b)	The EC must work harder at assembling and tasking the trans-committee teams
that increasingly are being required. In consultation with the committees, it must assign the
lead responsibilities, develop clear charges and terms-of-reference for projects, and carefully
allocate personnel and other resources.
(c)	Overall, the EC must establish and drive the SAB's agenda, with "agenda" meant
in both its grand and task-and-timing senses.
6.3 Transmittal of SAB reports. From early in its history on, the EC has served
to transmit almost all committee reports, regardless of where those reports originate within
the Board structure, to the Administrator. (The exceptions are reports from the CASAC,
which the Clean Air legislation specifies must go to the Administrator directly; in practice,
with the CASAC chair sitting ex officio on the EC, the CASAC thoroughly apprises the EC
of CASAC activities and coordinates them with other Board activities.)
Should the EC continue this transmittal? In what circumstances and to what extent
should the EC itself review and "second-guess" the expert committee members and
consultants who generate a report (excepting, of course, CASAC reports)?
Recommendations on Executive Committee transmittal of reports.
(a)	The EC should continue to reserve for itself the role of transmitting reports to the
Administrator, with the chair of the EC (who is the chair of the SAB) signing the letters of
(b)	At the beginning of an SAB inquiry the EC should concern itself principally with
the competence and appropriateness of the committee assigned to conduct the study, and

with the charge to the committee.
(c) When an inquiry has been completed and submitted to the EC for transmittal, the
EC should examine the extent to which the charge has been fulfilled, the adequacy of the
committee's consultation with other elements of the SAB with which there is overlapping or
spinoff concern, the clarity of the evaluative logic within the review, the quality of the report
as a communication (readability, focus, contexting, documentation), and plans for follow-
In general the EC should restrain itself from the temptation to review the
substantive details, no matter how intriguing those may be. But in an event that the EC is
not satisfied on the matters cited above, or believes that the Agency may not be acting in
good faith, or becomes aware of an allegation of undue bias or conflict of interest, the EC
should roll up its sleeves, delve into the problem (including the substance if necessary),
and work toward resolution.
From time to time the EC, from its broad perspective, may notice that a committee
has strayed into policy territory, overlooked some aspect of a problem, or drafted too
parochial a report, and can call for reconsideration. The consensus seems to be that there
is much merit in the EC's continuing to serve as the conduit for transmittal of reports to
the Administrator, but that the EC should try to improve its vetting process so that reports
are not unduly tinkered with or held up at the final EC stage. (Too, there is an interest in
freeing more of the EC's meeting time to address matters other than report transmittal.)
Perhaps the EC should ask a few of its members previously not involved with the study to
vet each committee report, and raise concerns for EC discussion only if warranted. Or
perhaps the EC mainly should screen the most important or contentious committee reports.
The EC should discuss these possibilities.
6.4 Upgrading the Executive Committee's leadership role. All of the
responsibilities outlined at the beginning of this section are being carried out by the EC
now. But each can be enacted even more vigorously. Section 4.2 of this report urged the
EC to take control of the SAB membership nominating process. Later sections of this
report will elaborate on the EC's horizon-scanning, agenda-setting, and representational

This Subcommittee urges the EC to lead the Board into a next phase wherein the
work of all the diverse committees and subcommittees becomes a more cohesive, more
integrated whole (this is not unlike what the Agency itself must strive for). The key - in
relating with the Agency and others, in setting priorities, in orchestrating activities, and in
allocating resourses - will be thinking and acting strategically.
7.1 Relations with the Agency, in general. How effective are the relationships
overall, and in different program and problem areas? And, should the SAB advise the
EPA laboratories or regional offices directly?
This report at the outset sketched two overall missions for the SAB vis-a-vis the
EPA: an aiding-and-extending mission, and an auditing-and-certifying mission. In
pursuing these the SAB tries simultaneously to be colleague, ally, counsellor, and quality-
control auditor to the Agency. This can generate conflicting tendencies on the Board's
part, and engender conflicting reactions by the Agency. Some Agency officials say they
view meeting with the SAB as being like "conferring with a friendly accountant"; others
see it as being like "going to the dentist." Perhaps the best way to think of the Board is
as loyal critic, with "critic" meant constructively.
An implication of this is that even as the Board strives to work cooperatively and
collegially with the Agency program and other offices, it must continue to maintain a
certain "distance" in order to preserve the impartiality and legitimacy of its advising.
The Board operates in many modes. It can advise in consultative fashion (for
instance, as the Agency has worked its way through a large number of drinking water
issues over the last several years, the SAB committees have discussed the problems with
the program offices continually, to mutual benefit). It can, of course, subject a problem to
elaborate, formal scrutiny, leading to a blockbuster report. It can conduct evaluative site-
visits, such as to the EPA laboratories. It can hold workshops, act as a sounding-board,
and brief top Agency officials.

Recommendation on the Administrator as the addressee of formal SAB advice. For
formal purposes, the Administrator himself — or, at least, the collectivity that goes by that
name, "the Twelfth Floor" of headquarters, the Office of the EPA Administrator -¦ should
continue to be the primary recipient of formal SAB advice. It remains the Administrator's
prerogative to refer that advice to whatever offices within the Agency and elsewhere he
judges appropriate, secure Agency responses to the SAB that he can sign his name to, and
take action.
The SAB opposes using multiple channels for formal, final advice-flow (even while
it encourages using many channels for informal consultation). Any issue important and
complex enough to warrant a formal request for SAB advice should be an issue that the
Administrator is concerned about. The SAB wants never to become interposed on issues
between the Administrator and his many offices and laboratories. Moreover, the SAB
believes that the Administrator's Office should be aware of all major advisory
communications, so as to properly integrate and lead the rather dispersed agency's work.
Recommendation on SAB requests for response from the Administrator. The SAB
should continue routinely to request that the Administrator provide timely, written responses
to formally transmitted SAB advice.
From 1984 to the present, the Administrators have willingly provided this feedback.
When an SAB report arrives in the Administrator's Office, that Office's tracking system
assigns the response-drafting task within the Agency, and notifies the SAB Office of the
date the response is expected (usually a matter of weeks after receipt of the SAB report).
If the Agency asks for an unusually long response lag, the SAB and the Agency negotiate
The resulting dynamic two-way interactions have been mutually informative and
engaging, have helped coordinate advice rendered with advice requested, and have proved
to be an effective internal Agency management device as well. SAB advice thus does not
simply "fall into a black hole." Even if the Agency disagrees with points of advice, the
Board becomes apprised of the reasoning; and the Board may ask for reconsideration.

These two protocols ~ transmission of SAB findings directly to the Administrator,
and provision of written responses from him -- foster accountability, and they generate
public documentation of rationales and responsiveness besides.
7.2 Potentially-SAB-relevant EPA program and research offices. The
relationships between the SAB and the Agency offices differ from area to area. Asked
what proportion of the EPA's major activities are one way or another brought to the SAB
for some action, most observers guesstimate about 50%. The exact number doesn't matter.
What is clear is that some program offices (Drinking Water) have a history of working
closely with the Board, while others (Pesticides and Toxic Substances) do not.
Occasionally the Board conducts a study — such as Future Risk in 1988, and the
current study of Relative Risk-Reduction Strategies -- expressly for the Administrator's
Office as the primary client. Recently it has reviewed several issues for the Agency's
multiprogram Risk Assessment Forum.
For mental surveying of the Agency's territory it is useful to think through the list,
below, of the Offices within various Assistant Administrators' ["AA"] domains that might
be expected to be clients for SAB advice; some of these work with SAB routinely, some
rarely do, and some have in-between relationships:
AA for Water
Drinking Water
Municipal Pollution Control
Water Regulations and Standards
Marine and Estuarine Protection
Ground-water Protection
Wetlands Protection
AA for Solid Waste and Emergency Response
Emergency and Remedial Response
Solid Waste
Underground Storage Tanks
AA for Air and Radiation
Radiation Programs
Air Quality Planning and Standards
Mobile Sources
Atmospheric and Indoor Air Program

AA for Pesticides and Toxic Substances
Pesticide Programs
Toxic Substances
AA for Research and Development
Research Program Management
Modelling and Monitoring Systems and Quality Assurance
Environmental Engineering and Technical Demonstration
Environmental Processes and Effects Research
Health Research
Health and Environmental Assessment
Technology Transfer and Regulatory Support
[The Laboratories]
AA for International Activities
AA for Policy, Planning, and Evaluation
Policy Analysis
Standards and Regulations
Pollution Prevention.
This Subcommittee is not in a position to generalize about the robustness of the
particular relationships between these offices and SAB committees. For now, suffice it to
say that they vary greatly, and that both the EPA offices and the SAB committees should
be encouraged to re-explore the possibilities for improving the interactions.
7.3 Advising EPA laboratories and regional offices. Although the SAB
potentially stands ready to advise any component of the Agency, it has been reluctant to
advise non-headquarters units directly.
Even what may at first appear to be exceptions, usually aren't. For example, at
present a subcommittee is reviewing aspects of aquatic sediment-quality criteria, at the
request of a regional administrator; but the review is a generic one that will have
implications for all of the regional offices, and the SAB will transmit it to the
Administrator, who presumably will send it to all relevant offices.
On many occasions the SAB has reviewed EPA laboratory programs, as to their
mission and focus, quality and relevance of research, competence, facilities, and other such
attributes. But although these reviews surely have given useful guidance to the Laboratory

Directors, the primary formal recipients of the advice have been the EPA Administrator and
the Assistant Administrator for R&D.
Recommendation on advisins non-headquarters EPA units directly. The SAB should
consider advising the EPA Laboratory Directors or Regional Administrators directly, but
only if this is requested by the EPA Administrator.
7.4 Relations with other advisory bodies. Several groups besides the SAB advise
the Agency. How independently of each other should all of these advisors operate?
Should the SAB revise its coordination with the Federal Insecticide, Fungicide, and
Rodenticide Act Science Advisory Panel (FIFRA SAP)? At present that Panel is
independent of the SAB, and there hasn't been much coordination. However, the FIFRA
SAP chair is ex officio a member of the SAB Executive Committee, and the new chair has
expressed an interest in becoming more involved with the SAB. The detailed, formal,
registration-oriented and commercial proprietary aspects of the SAP's work is thought by
some observers to preclude merging within the SAB structure. On some problems, such as
neurotoxicity testing protocols, SAB and SAP have worked together. At present they are
joindy examining issues having to do with acetylcholinesterase inhibitors (which are
relevant for regulating pesticides and many other chemicals).
Recommendation on SAB- FIFRA SAP coordination. Every effort should be made to
upgrade the coordination of the SAB with the FIFRA SAP on scientific principles, such as
approaches to drawing inferences from experimental data.
(In passing let it be noted here that not all pesticide issues should automatically be
assigned to the FIFRA SAP; many have implications for groundwater, drinking water, and
other broad Agency, and therefore SAB, responsibilities.)
The Biotechnology Science Advisory Committee (BSAC), which was spawned by
the SAB several years ago, also works on its own ~ mainly, so far, on microbial pest-
controls. Whether there is need for coordination with the SAB at this stage is not clear,
perhaps because the biotechnology group is small and still getting underway. Almost

certainly coordination is desirable, just as;with the FIFRA SAP. The SAB? should explore
the .desirability of recementing its relationship with the BSAC.
A variety of other panels are assembled by. Aeencv offices from time to time for
advice (most do not report to the Administrator). Many of these'are one-time, ad hoc
groups that lack formal standing and are not coordinated with the SAB. But some, such as.
the National Drinking Water Advisory Council (NDWAC) and the National Air Pollution
Control Techniques, Advisory Committee (NAPCTAC), do have formal standing, have
coordinated with the SAB in the past, and might become closer partners in the future. The
newly upgraded SAB Drinking Water Committee is committed to developing better
relationships with the NDWAC, as is logical.
How should the SAB work with non-EPA advisory groups?
The SAB interacts with such organizations as the National Research Council (NRC)
and the National Council on Radiation Protection and Measurements mainly yia the
personal participation of some SAB members in the other organizations. Joint projects
seem rarely to have been undertaken, but on several occasions the SAB has helped initiate
projects by the NRC or other organizations, such as bv ureine the EPA to commission anH
fund them.
For synergism, SAB committees may wish to explore informal liaison with other
advisory groups. The EHC might, for example, pursue common cause with counterpart
groups that advise units of the Department of Health and Human Services, such as the
National Toxicology Program and the Agency for Toxic Substances and Disease Registry.
And the Executive Committee might work in a more coordinated way with the NRC Board
on Environmental Studies and Technology, whose agenda constantly overlaDS that of the
Almost certainly the SAB would welcome an opportunity to work in some way with
panels established by the White House Office of Science and Technology Policy, on such
problems as global climate or carcinogenic,risk assessment,-or with a;resurrected Council
on Environmental Quality.

7.5 Relations with other advisory clients. Beyond advising the EPA, should the
SAB make more effort to advise the Congress directly? How about other regulatory
On occasion the SAB is asked to present testimony to Congressional committees on
issues that the Board has reviewed. For the last four years, for example, a member of the
SAB Office of Research and Development [ORD] Budget Review Subcommittee has
testified before the Subcommittee on Natural Resources, Agriculture Research and
Environment of the House of Representatives on the adequacy of the President's proposed
budget for the ORD. Also, upon completion of the study Future Risk, the chair of the
authoring Research Strategies Advisory Committee testified before that same Congressional
Subcommittee on the desirability of establishing an Environmental Research Institute.
Another way the SAB helps ensure high-quality information for the Hill is by
reviewing Agency reports, at proposed-final-draft stage, prepared at the request of the
Congress. For instance, in 1989 a subcommittee reviewed two elaborate Agency draft
reports to Congress on global climate change: Potential Effects of Global Climate Change
on the United States, and Policy Options for Stabilizing Global Climate; the SAB input
helped improve and certify those ambitious interdisciplinary reports.
To do a proper job in some areas, the SAB has to examine not only the EPA's
work but that of other agencies having intersecting interests. For example, the Indoor Air
Quality Committee is required, under the Superfund Amendments and Reauthorization Act,
to review the entire federal indoor air program; the Committee has performed these
reviews, although it has found it difficult to obtain adequate information on the non-EPA
On at least one occasion the SAB has fulfilled a request to review an issue for
another federal agency (the Consumer Product Safety Commission), which lacked the
necessary advisory resources. This is viewed as having been an unusual exception.
These initiatives notwithstanding: The SAB views its primary advisory relationship
to be that with the EPA Administrator.

7.6 Openness and relations with the public. The SAB operates quite openly, in
the tradition of science and in the spirit of the federal "sunshine" laws. It publishes
notifications of its meetings in the Federal Register, routinely opens its meetings to the
public, keeps minutes of meetings, safeguards against conflicts-of-interest, releases its
documents freely, gives consideration to statements conveyed to it from the public, and
reaches out to especially interested publics.
The only meeting sessions that are closed to public observers are some that involve
planning, report-drafting, examination of unreleased Agency budgets, or discussion of
sensitive SAB personnel issues. The Board is always open to receiving written statements
from any source, so long as they address relevant scientific issues. Usually committees are
willing to allocate brief segments of meetings to listening to remarks by members of the
public, again so long as they focus on scientific matters. Members of the press and
representatives of various outside organizations routinely attend SAB meetings.
Sometimes the SAB window-onto-the-Agency role is exercised vigorously, as when
non-SAB scientists submit scientific input. If the SAB committee is convinced, it may
well shepherd the information into Agency deliberations and secure a response.
SAB tries routinely to distribute its reports to all public parties the SAB can
identify as possibly being interested. It welcomes additions to its mailing lists. SAB
reports now are deposited in all EPA libraries around the country, and they are placed on
file with the National Technical Information Service, which assures.long-term access by
libraries and readers. (The Board could help public attendees follow SAB meeting
discussions by making available at the meeting extra copies of the documents being
examined; this often is done, but not always.) The SAB Staff Director's Annual Report
provides an excellent once-a-year retrospective on Board accomplishments.
Although SAB reports are circulated to many EPA offices, some Agency
commentors say that they wish that the documents were circulated more extensively within
the Agency. Both the SAB staff offices and the Agency's own report-distribution system
should review their report constituencies to be sure that all relevant EPA offices are
covered. Periodically the SAB should circulate a listing of its reports, with abstracts.

As the Board reaches out, now, beyond circles of aficionados who follow the
Board's work routinely, it must make sure that its report titles crystallize the topics of the
reports, that the executive summaries encapsulate the reports' essences, and that the texts
make the context of the advising clear. Some SAB reports, especially those with a
specialized focus, have not been very accommodating to nonspecialist readers, or to
potential readers who need to be able to judge from a title listing or report summary
whether they wish to obtain and read the full report. Committees should make efforts to
improve these aspects of their documents.
8.1 Setting priorities and the agenda. Is the process by which the Board decides
to undertake projects appropriate? How are SAB concerns meshed with Agency concerns?
Should more explicit criteria be developed for selecting projects and setting priorities?
SAB initiatives have many origins. Some come from Agency program offices,
laboratories, or regional offices. Some come from the Administrator's Office. Some come
from the Hill. Some come from SAB members or committees, or the committee staff. A
few come from SAB consultants or the public. Whatever their origins, however, all ideas
are referred either to the Administrator or the SAB Executive Committee, which, working
through the SAB Staff Director, jointly consider whether and how to undertake the
advisory project.
Some SAB reviews, such as CAS AC's reviews of the scientific considerations
involved in the National Ambient Air Quality Standards (NAAQS) for major pollutants
regulated under the Clean Air Act, are committed to long in advance (the NAAQS reviews,
for example, are mandated by the Act and come to the CASAC with considerable advance
notice). Some are triggered by emergencies.
Many SAB projects are responses to Agency requests; some are initiatives taken by
the Board. As should be expected, often the SAB induces the Administrator to formally
request SAB advice.

Probably it is too sweeping, but an extreme operating principle would be for the
Administrator to identify all upcoming major Agency actions, and offer the SAB the
opportunity to undertake review— an SAB "right of declination to review." Terms of
review (such as timing) would be negotiated with the Administrator. Of course the
Administrator would retain the prerogative to request any advice he desires.
Occasionally the SAB declines an Agency request, on grounds that the request is
not clearly articulated, or that the issue hinges on extra-scientific considerations that the
Board is not an authority on, or that the problem is not sufficiently important relative to
other demands as to warrant SAB attention.
Sometimes the SAB tasks itself. An influential example was the SAB's "scoping"
of municipal waste incineration in 1986-87, which will be discussed later. In 1988 the
Environmental Engineering Committee took it upon itself, with the approval of the EC, to
survey and critique the Agency's application of a wide variety of mathematical models
(sophisticated and simplistic, up-to-date and outdated); the Committee prepared a report,
and then the EC endorsed a resolution of concern to the Agency on this generic problem.
Self-initiation seems to be an increasingly important mode for the SAB.
There is nothing specifically wrong about the way in which issues are referred to
the SAB or are generated by the Board. Multiple input is desirable. But some committees
need to cultivate their relationships with the relevant EPA program offices and laboratories
in their areas, to elicit more active, effective, and timely SAB advisory assistance.
And to act more strategically, the Board needs to move toward a more regular
process for sorting among all the possible advisory projects and deciding which ones to
undertake, and which of those to subject to a quick looking-at and which to a full-dress
Recommendations on SAB asenda-settins.
(a) The various SAB committees should devote much more effort to scanning the
horizon and setting their agendas - tasks, tactics, timing, resource and talent needs. On
many issues the committees are much better positioned than the Executive Committee is to

recognize emerging issues or anticipate difficulties.
(b)	The Executive Committee, actively involving the standing-committee chairs, all of
whom are EC members, should continually scrutinize the agenda of the Board as a whole so
as to make the Board most responsive and most productive. It should consider engaging in
more brainstorming, perhaps along with high Agency officials, to identify emerging issues
that should be considered for the SAB agenda.
(c)	The Agency itself should be urged to identify upcoming major Agency actions
whose scientific aspects might warrant SAB attention, and more systematically sort out and
express its priority preferences for the SAB agenda. The SAB agenda should continue to be
negotiated between the Board and the Agency, with every effort made to focus on issues
having the highest importance.
8.2 Criteria for undertaking SAB studies. Although obviously the Board has a
sense of what is worthy, "weighting" criteria would help determine whether to undertake
advisory tasks.
Recommendation on criteria for selection of SAB projects. The Board should develop
criteria like the following to guide selection of SAB projects. For instance, proposed SAB
projects might be assigned precedence according to how intensively they will:
- impact on overall environmental protection:
-- address novel scientific problems or principles;
-- integrate science into Agency actions in new ways;
-- influence lone-term technological development;
-- respond to emergencies;
-- deal with problems that pervade several EPA domains:
-- address problems that transcend federal-aeencv or other organizational
-- strengthen the Agency's basic capabilities;
-- serve Congressional or other leadership interests.
The more strongly an issue meets several criteria, the stronger the impetus would be
to commit to SAB review. Such a list of criteria would aid the Board both internally and
in its agenda-setting with the Agency. The criteria should be taken as considerations, as

guides, not as rigid requirements.
To illustrate, notice how some of the SAB's more influential recent investigations
have de facto met such criteria: impact on overall environmental protection (consensus on
the health and environmental effects of ozone air pollution); address novel scientific
problems or principles (inferences allowable from observation of thyroid carcinogenesis in
rat assays); integrate science into Agency actions in new ways (application of ecological
knowledge to contemplated regulation of marine sediments); influence lons-term
technological development (efficacy and cost-effectiveness of drinking-water-treatment
technologies); respond to emergencies (whether and how to deploy specially-cultivated
bacteria to help remediate the Alaska oilspill); deal with problems that pervade several
EPA domains (carcinogenicity classification of lead compounds, which are regulated in air,
surface waters, drinking water, solid waste, and other milieus); address problems that
transcend federal-agency or other organizational boundaries (coping with the effects of
global climate change); have potential to strengthen the Agency's basic capabilities
(effectiveness of EPA's scientific career-development ladder);, serve Congressional or other
leadership interests (indoor air pollution).
8.3 Timing and timeliness. Are there aspects of the SAB's work in which timing
can be improved — in becoming involved with problems, in defining tasks, in performing
and delivering products?
The SAB can get involved at any attention-stage of an, issue problem definition;
research planning, pre-regUlatory assessment, whatever. In most instances the SAB is best
in a position to address rather broad, strategic scientific aspects of problems before the
Agency commits itself , to. formal remedy. After the Agency has set policy, or promulgated
regulations, or issued guidance to state governments, usually it is too late to call for review
of the scientific bases upon which the actions were taken. Afterthought reviews tend to be
tedious and ineffectual. So, again, agenda-setting is key, and it depends upon both the
Agency and the SAB.
Always there is the question of how to synchronize Agency actions with scientific
progress (such as the completing of research, or the updating of basic data, or the releasing

of monitoring results). Obviously the Agency has to decide when it will have to take
protective action. Sometimes the SAB can advise on propitious pacing. In some instances
partial revisiting of an analysis can be scheduled, for a later time when new findings are
expected to become available.
How far along toward final EPA action should the SAB "follow" an issue whose
scientific bases it has advised on initially? In some cases the Board helps the Agency
establish fundamental premises and then disengages; in others it checks later to be sure
the science is preserved all the way through into application. On major air regulations, the
CASAC reviews the scientific background (criteria documents and the like) early in the
attention cycle; then it reviews the scientific aspects of the "staff paper" the Agency
eventually prepares to establish the ground for the Administrator's regulatory decisions.
Informal follow-through, at least, generally makes sense on any issue that earlier has been
important enough to have warranted SAB examination. The Agency and the Board should
deliberate this for each project.
Timeliness of SAB advising has improved substantially over recent years. The
agenda-setting reforms suggested should help further. Perhaps the Executive Committee
can streamline its vetting of proposed committee reports. As the next section will
complain, the document-processing bottleneck needs remedying. To better manage its
timing, the Board should set up a system for tracking the progress of all of its studies,
from proposal stage to reporting to follow-through.
As the quick SAB response on bioremediation of the Alaska oilspill demonstrated,
"crash" response certainly is possible. But it has its difficulties. Assembling a proper
team of experts takes a little time. Travel has to be paid for; a deeper financial reservoir
would help meet emergency requests. Individuals on the SAB roster always can be tapped
quickly, as individuals, if the Administrator requests informal advice. But this cannot be
said to constitute formal "SAB" advice. Deliberations involving more than one Board
member may have to meet various Federal Advisory Committee Act provisions, although
these can be officially waived in emergencies. And of course running proposed advice
through full SAB (including Executive Committee) review for formal endorsement and
transmittal is time-consuming.

Some of the most awkward timing in the past has been driven by court orders or
other external pressures that have truncated the normal lead-time and violated the usual
pacing of Board review. The Board has tried to adjust and be responsive anyway. On a
few occasions this has meant that a committee review has had to be reported out without
being vetted and endorsed by the Executive Committee. It is in the best interests of the
nation that the Agency not allow the Board, or the Board allow itself, to be abused on
timing. Often some release of time-pressure can be negotiated, even on court-driven
Recommendation on improving timing and timeliness. Early along in contemplated
advisory exchanges, the relevant EPA offices and SAB committees should consult as to the
nature of the proposed advising; reach clear agreement on which aspects of the subject will
be examined, and how; negotiate as to timing, interim reports and checks, deadlines,
procedure, staffing, and documentation needs; and carefully husband and schedule the use
of SAB talents and staff support.
9.1 Staffing. Although this report has not mentioned the SAB staff all along, it
should be understood that the staff help facilitate every aspect of SAB activity.
The SAB is supported by eight professional staff officers: a Staff Director, six
Executive Secretaries (who are assigned to the Board committees and legally serve as the
Designated Federal Officials for those committees under Federal Advisory Committee Act
regulations), and a Program Analyst (who manages budgetary, personnel, and logistical
matters). Eight Staff Secretaries complete the office.
The key to appreciating the staffing roles is recognizing their "in-betweenness." The
staff are employed by the EPA, with the Staff Director reporting to the Deputy
Administrator, and they serve within the Agency's personnel system. The Board's budget
is allocated entirely from the Deputy Administrator's Office budget. But the substantive
direction and overall task agenda of the SAB and its staff are, or at least should be, set by

the Board itself. Thus the staff must serve in-between. Also the staff must deal with the
difficulties of working with the dispersed and very busy SAB members, who serve
voluntarily, part-time, and on-the-run.
By far the most important duty for the SAB Staff Director and Executive
Secretaries is serving as two-way ambassadors: they must represent Board concerns to the
Agency, and Agency concerns to the Board.
Operationally, the staff officers make things happen: they assist with planning the
committees' work, nominating and renewing the appointments of members and consultants,
safeguarding against conflicts-of-interest, scheduling and planning meetings, arranging for.
travel and reimbursement of travel expenses, running meetings and teleconferences, drafting
and revising reports, moving an enormous amount of paper in many directions, assuring
compliance with all the applicable Federal "sunshine" laws, and interacting with the public
and the newsmedia. A staff officer is required to be present at every committee meeting.
By planning, conferring, scheduling, and briefing, the staff help mesh the SAB's work with
that of the Agency.
Overall, the staff must be competent at summarizing and integrating complex
environmental scientific analyses; at planning and organizing; at working with a diversity
of people under pressure; and at writing and communicating fluently.
Crucial roles are played by the SAB Staff Director. He must work very closely
with the Chairman of the Board and the committee chairs, manage the staff's work, serve
as the SAB's most active liaison to the Agency, and convey Agency concerns to the Board
and SAB staff.
The Subcommittee (and, it certainly seems, the Board) finds the current professional
staff generally to be competent, energetic, and dedicated. Much of the time, the
professional staff members have to work under near-overload conditions. They perform
heroically. But although those staff officers might not say it, "burnout" occasionally
threatens. And, additionally, in the past year or so several prolonged staff-position
vacancies have added to the drag. Certainly heroism is expected, but it should not have t(

be required all day every day.
The Agency should see to it that the SAB professional staff positions are highly
rated and rewarding. Much of the Board's productivity depends on its being assisted by a
Staff Director and Executive Secretaries who are scientifically competent and who are able
to cultivate solid working relationships with all involved parties, synthesize and express
advisory views, represent the Board impressively to the public, and exercise leadership.
Incidentally, to the public the job title "Executive Secretary" fails to connote the
demanding responsibilities these officers fulfill; thought should be given to revising this
The Board and the Agency must ensure that personal career development is
provided for the staff. Staff members who become outdated or "lose touch" with the
technical fields they serve cannot be expected to perform at state-of-the-art levels.
Opportunities and funds should be provided for mid-career re-education and for travel to
important professional conferences. Probably it would be productive if both the SAB Staff
Office and a subcommittee of the Executive Committee (separately and then together)
reviewed the staff career-development needs and opportunities.
9.2 The Board's responsibilities toward the staff. A strong factor in SAB
productivity is staff task-setting. Much of the responsibility for determining the staffs
workload and scheduling resides with the Board. As in all of life, short-term and tangible
demands - such as revising the countless details of committee reports - tend to consume
the staff's efforts, to the exclusion of longer-term task exploration and planning. The
Board should try to be mindful of the staff workload and pacing, and help match work
demands to staff capabilities.
Recommendation on husbandine of staff efforts. Committee chairs and members
should help budget and protect the SAB staff officers' time and efforts. Also they should
encourage their committees' Executive Secretaries, as important parts of their jobs, actively
to pursue liaison with the Agency program and other offices - to cultivate vigorous working
relationships, communicate about issues arising, negotiate expectations for reviews, and

follow through on advice rendered.
In general: These professional-staff jobs are demanding; the staff play essential
roles, and they play them well; everyone concerned should help bolster the staff's work,
and award proper recognition to staff accomplishments.
9.3 Staff Office operations. Without question, the logistical support for the SAB
and its professional staff needs improvement. The Board needs substantial Agency help
with this.
Finding on SAB Staff Office operations. The Subcommittee finds, and has been urge
by many Board members to emphasize, that the clerical and secretarial support services are
very inadequate for handling the relentless SAB office workload of telephoning, planning
meetings, arranging travel, reimbursing expenses, and preparing, revising, logging,
reproducing, and distributing large volumes of documents. Clerical performance is not
uniformly impressive (grade-level and salary limits may be a problem).
Many of the problems just are the result of overload. In the past few years turnove?
in support staff has been high. The SAB offices chronically have had to work seriously
shorthanded. These deficiencies have unduly held up preparation of Board reports and
impeded other work.
Because the SAB Office is shorthanded and overloaded, it is unable to perform
effectively; morale suffers; overload worsens; performance suffers; personnel
recruitment suffers.... This state of affairs urgently has to be remedied, in part to ease the
burden on staff members who have struggled devotedly to "hold the fort."
Concurrently with the present SAB Subcommittee's review, at the request of the
SAB Staff Director, the EPA Division of Management and Organization and the Office of
the EPA Comptroller are conducting reviews of the SAB Staff Office. Those reviews --
which will audit many aspects of staff recruitment, work roles and workload, office
organization, operating procedures, office facilities, computer efficiency, and budgetary
resources ~ are scheduled to be released to the SAB staff and membership at about the

same time as the present report. This Subcommittee has coordinated with these
complementary reviewers, looks forward to learning their conclusions, and deeply hopes
that these managerial reviews will recommend means for relieving the clerical and other
The SAB's computer capabilities (hardware, software, and training), which can
powerfully assist with report drafting and make up for some of the secretarial
shortcomings, have been less than optimal. Improvements will provide high gains in
productivity at relatively low cost. True systems are needed, not just assorted hardware.
Some upgrading is being pursued now, and the SAB is converting uniformly to the
wordprocessing program "WordPerfect®, Version 5.0." The current expansion of these
capabilities (again, bolstered by the management audit) should be watch sd to see whether it
rectifies the computer inadequacies.
Recommendation on upgrading of SAB Office computer efficiency. The Board should
encourage the SAB Office to invest the infrastructural effort required to survey the
capabilities of its computers and those available to the EPA, acquire the necessary software,
set up mailing lists and tracking systems and document preparation systems, train all of the
staff appropriately, and in general master and prepare to make the fullest use of computers.
9.4 Operating budget. Currently all of the SAB budget is allocated from the
Deputy Administrator's Office budget. The occasional temptation to charge SAB costs to
programs or laboratories under review is generally rejected by the Board as having
potential to compromise the SAB's independence.
The FY 1989 SAB budget was modest, totalling about $1,491,000. Of this total,
some $425,000 went to member and consultant compensation, $715,000 to staff
compensation, $288,000 to travel, and $63,000 to office and miscellaneous expenses.
Even as the workload has substantially increased, the past several years have
brought budget constraints to the SAB. Several projects have been stunted, or postponed
or aborted, because of lack of funds, especially the travel funds that are so essential to the
functioning of a dispersed voluntary board.

This Subcommittee cannot provide a detailed budget analysis here. But -- with the
encouragement of many Board leaders ~ it feels obliged to point out that the resources
committed to the SAB are extremely low for such an active board advising an agency the
size and technical complexity of the EPA, and that the cost-effectiveness is very high. The
leverage afforded the Agency by tapping the nation's scientific community via the Board is
enormous. (And, incidentally, a sizable indirect contribution is made by the members' and
consultants' home institutions, which usually do not recover the overhead costs they incur
in providing secretarial, photocopying, and other services in support of SAB projects.)
As a minimum, if the Board helps improve the effectiveness of even one major
research or regulatory program, it in effect "pays for itself ~ but obviously a budget that
makes this possible has to be invested in the first place.
Finding and recommendation on the SAB budeet. The Subcommittee believes that the
present SAB budget is inadequate for the expectations, demands, and opportunities of the
Board's work. The Subcommittee strongly urges the Agency and the Congress to tend the
SAB's budget as carefully as the budget of the Agency itself
Recall from early in this report that the functions the SAB currently performs
-- Reviewing the quality and relevance of particular regulatory science;
-	Reviewing generic regulatory-scientific approaches;
-	Reviewing research programs;
-	Reviewing the technical bases of various applied programs;
-- Advising on infrastructural and technical management issues;
-	Advising on short-notice problems; and
-	Advising on broad, strategic matters.
To these functions the Board should consider adding three regular functions that
would not be entirely new but would be enhanced versions of things already being done

but in low-key: providing forums and pursuing outreach; advising on aspects of
implementation and communication; and helping the Agency anticipate problems and act
even more strategically,
10.1	Providing forums and pursuing outreach. As was noted at the outset, in its
own working the SAB acts as a forum, bringing into the Agency diverse views and
providing a focus even for both indirect and unsolicited inputs. Should the SAB go
further, as by convening workshops on issues?
The consensus seems to be that the SAB should at least help initiate and design
informal workshops on uncertain, highly-contentious scientific issues on which vigorous
direct exchange among experts, or between experts and policymakers, would be
constructive. It has done this in the past on some issues in neurotoxicology, the
toxicological interpretation of mouse-liver tumors, and other topics. The SAB can suggest
that the Agency convene small conferences, or join other organizations in doing so. Or the
SAB can recommend that the Agency commission professional societies or the National
Research Council to hold seminars (perhaps within already-scheduled larger conferences).
Probably the best role for the SAB is identifying the need for stocktaking, then
catalyzing and participating in — not leading — these workshops. However, it wouldn't in
principle be bad for the SAB itself to hold a workshop. In all events, SAB's imprimatur
should be safeguarded and not lent to efforts that don't really bear considered SAB
A simpler and more direct way for the SAB and the Agency to hear leading
opinions is to invite several experts to present briefings and join in discussion at SAB
committee meetings. This has proved enlightening in the past.
10.2	Advising on implementation and public communication. Should the SAB
evaluate and advise on the effectiveness of program implementation, technology transfer,
risk communication, or other such issues?

Consensus simply isn't clear. Opinions differ. Several observers suggest that the
SAB expand its coverage and: (a) help develop context surrounding decisions involving
but not limited to scientific findings (such as analysis of health "stakes," or the handling of
scientific uncertainties); (b) evaluate strategies and programs for informing the public
(such as on how to cope with household radon) and changing the public's behavior (such
as urging recycling); and (c) evaluate the effectiveness of EPA's implementation of
various programs.
There isn't any inherent reason why some such issues couldn't be examined by the
SAB, except that the appropriate talents would have to be recruited. In 1988 a few
members of the Radiation Advisory Committee productively reviewed the EPA's draft
Citizen's Guide to Radon; although the Committee did not, as a committee, review the
document, presumably it could have. There have been other examples. But the technical
aspects of many implementation and communication issues are hybridized with political, or
managerial, or funding, or other non-scientific aspects in ways that create difficulties for
SAB review. How one views all this may hinge in part on whether one considers
psychology, economics, sociology, and the like to be "science." There is potential for
backlash if the SAB is publicly perceived to be meddling in extra-scientific policy and
managerial matters.
The SAB should explore these domains vigorously but cautiously. The question is
not whether the Board could generate answers (naturally it could); the question is whether
by doing so it might stretch and weaken its natural-science authority. Much hinges on
how the problems are defined and shaped for SAB examination. Perhaps the SAB should
simply conduct a few trials: broaden its membership by a few leading social scientists
with environmental experience, try a project or two, and see how productive the exercises
turn out to be. These are initiatives the Executive Committee should discuss.
Unquestionably such issues as education, program implementation, and cost-
effectiveness deserve scrutiny by outside experts. Perhaps the Agency should establish,
separate from the SAB, a policy and implementation analysis panel, reporting to the AA
for Policy, Planning, and Evaluation (PPE); Such a panel should involve not only social
scientists and communication experts but aiso some natural scientists skilled at interpreting

science for nonscientists and integrating science into policy decisions. Of course the EPA
can set up such a panel regardless of whether the SAB recruits more social scientists and
takes on some of these issues. If both plans are pursued, overlap problems will have to be
sorted out. The pool of social scientists and policy analysts that would be drawn on would
be similar for the SAB and for a PPE group — but die auspices would be fundamentally
different, the questions could be cast somewhat differently, and advisors serving PPE might
"wear different analytic hats" from the ones worn when serving on the SAB. If the
Agency does establish a PPE panel and the SAB does not expand its coverage, some
projects would have to be conducted jointly between the two groups.
10.3 Helping the Agency be more anticipatory and strategic. It is surpassingly
important for both the Agency and the SAB to anticipate environmental issues and act
more strategically. Easy to say, hard to do.
Hindsight shows us how much better off the country (and the world) would be if
we had controlled industrial wastes earlier and more effectively. The same with protecting
groundwater. The same with recycling of materials, dealing with asbestos, and protecting
urban air. Examples are ruefully obvious.
On many issues like these, the SAB should try to catalyze Agency action. Some
agency-leading SAB advising has been quite constructive. In 1986, frustrated that the
Agency was not keeping up with (much less leading) the rapidly growing movement
toward incinerating municipal wastes, the SAB undertook a fairly elaborate survey of the
scientific dimensions of that enterprise; . as the study progressed, the Agency took its own
initiatives and requested that the SAB review an incineration research plan and a health-
risk-assessment methodology for incinerator emissions; the SAB provided the requested
reviews, published its own survey report, and is still conducting two follow-on studies (of
incinerator ash problems and of products of incomplete combustion).
Sometimes the Board finds that the Agency isn't easily moved; this may or may
not be the fault of the program office in the area. To mention an example, several SAB
expressions of concern about inadequacies of EPA's research and scientific coverage of
nonionizing radiation problems have been unavailing.

The SAB committees should scan ahead for environmental problems that are
impending and underattended, and for technical and other possibilities for addressing them,
and raise alarms and opportunities forcibly to the attention of the Agency. On some
problems, as it did with municipal waste incineration, the SAB may find demonstration-
value in conducting "scoping" studies to survey the parameters of the problem. The
Executive Committee should encourage and amplify these efforts.
Environmental "horizon-scanning" and issue-identification should be a portion of
every Executive Committee meeting. Committee chairs should be expected to bring
forward concerns from their committees. Briefings by Agency officials or others might be
requested. The SAB Annual Meeting might provide a special opportunity to set out a
menu of topics to be screened for SAB and Agency attention.
As for being strategic, the challenge - again, for both the Agency and the SAB -
is to identify and take on the most genuinely threatening problems, and not let Agency
efforts get frittered away on the swarms of nagging but lesser issues. Environmental
protection should be viewed as investment. Priority-guiding exercises, such as the
Agency's current relative-risk-reduction project on which the SAB is advising, may help.
So can environmental monitoring, early warning, and environmentally-sensitive technology
development. On all of these matters, the SAB can provide assistance.
The Mission and Functioning Subcommittee hopes that the entire Science Advisory
Board network — members, consultants, committees, staff, other colleagues -- will become
engaged in responding to this report.
The Subcommittee also hopes that the Agency will work through the report,
examine the advisory endeavor from its perspective as the SAB's principal "client," and
then explore with the Board possibilities for reducing obstacles, meeting challenges, and
seizing mutual opportunities.

SAB-CASAC-89-001 Possible Listing of Acid Aerosols as a Criteria Pollutant
SAB-CASAC-89-002 Acid Aerosol Research Needs
SAB-RAC-89-003 National Emission Standards for Hazardous Air Pollutants: Standards
for Radionuclides
SAB-EHC-89-004 Thyroid Follicular Cell Carcinogenesis
SAB-EHC-89-005 Male and Female Reproductive Risk Guidelines
SAB-EHC-89-006 Lead in Drinking Water
SAB-EHC-89-007 Drinking Water Contaminants Involved in Phase II Draft
Regulations: Treatment Technologies
SAB-EHC-89-008 Health Assessment Document for Phosgene
SAB-CASAC-89-009 CASAC Advice on Acid Aerosols
SAB-IAQC-89-010 EPA Indoor Air Quality Implementation Plan
SAB-EHC-89-011 Drinking Water Contaminants Involved in Phase II Draft
Regulations: Analytical Methodologies
SAB-EEC-89-012 Resolution on the Use of Mathematical Models by EPA for
Regulatory Assessment and Decision-making
SAB-RSAC-89-013 Office of Research and Development's Core Research Program
SAB-EC-89-014 Fiscal 1990 President's Budget for the Office of Research and
SAB-EC-89-015 Scientific and Technological Achievement Awards
SAB-EC-89-016 Review of the Report to Congress: Potential Effects of Global
Climate Change on the U.S.
SAB-RAC-89-017 Radon Measurement Profiency Program
SAB-CASAC-89-018 Lead NAAQS Exposure Analysis Methodology and Validation
SAB-CASAC-89-019 NAAQS for Ozone: Closure on the Office of Air Quality and
Planning and Standards Staff Paper (1988) and the
Criteria Document Supplement (1988)

SAB-EETFC-89-020 Evaluation of the Proposed Guidelines for Exposure-Related
SAB-CASAC-89-021 Clinical Research Program of the Health Effects Research
SAB-EC-89-022 Five-Year Office of Research and Development Outlook
SAB-EETFC-89-023 Alaskan Oil Spill Bioremediation Project
SAB-RAC-89-024 Office of Radiation Programs NESHAPS Background Information
SAB-RSAC-89-025 Evaluation of the Office of Research and Development's Preliminary
Skills Mix Assessment
SAB-RSAC-89-026 Evaluation of Career Ladders for Office of Research and
Development Field Scientific and Engineering Positions
SAB-EETFC-89-027 Evaluation of the Apparent Effects Threshold (AET) Approach for
Assessing Sediment Quality
SAB-EHC-89-028	Office of Drinking Water's Health Criteria Document for Cyanide
SAB-EHC-89-029	Office of Drinking Water's Health Criteria Document for Antimony
SAB-EHC-89-030	Office of Drinking Water's Health Criteria Document for Sulfate
SAB-EHC-89-031	Office of Drinking Water's Health Criteria Document for Thallium
SAB-EHC-89-032 Office of Drinking Water's Health Criteria Document for
Hexachlorocyclopentadiene and 1,1,2-trichloroethane
SAB-RSAC-89-033 Office of Research and Development Assistant Administrator's
Interim Guidance for FY 1991
SAB-EC-89-034 Review of the Report to Congress: Policy Options for Stabilizing
SAB-EEC-89-035 Office of Water's Proposed Sludge Use and Disposal Regulation
SAB-EHC-89-036 Mixtures Relating to Soime Phase II Drinking Water Regulations of
the Office of Drinking Water
SAB-EEC-89-037 Draft Pollution Prevention Research Plan: Report to Congress
SAB-EHC-89-038 Arsenic Issues Relating to Phase II Proposed Regulations From the
Office of Drinking Water

William W. Lowrance (Chair)
Senior Fellow and Director
Life Sciences and Public Policy Program
The Rockefeller University
1230 York Avenue
New York, NY 10021-6399
(212) 570-8679
Paul F. Deisler, Jr.
Visiting Executive Professor
University of Houston
c/o 11215 Wilding Lane
Houston, TX 77024
(713) 467-3080
Roger O. McClellan
Chemical Industry Institute of Toxicology
6 Davis Drive
Research Triangle Park, NC 27709
(919) 541-2070
C. Herb Ward
Professor and Chair
Department of Environmental Science
and Engineering
P.O. Box 1892
Rice University
Houston, TX 77005
(713) 527-4086