Crossroads:
Meeting Challenges
for Credible Science
The EPA Science Advisory Board
Accomplishments Report for Fiscal Year 2002
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Dear Readers:
On behalf of the U.S. Environmental Protection Agency' s Science Advisory Board, I am pleased to present the first
SAB Accomplishments Report.
This report highlights the SAB' s success in providing comprehensive analyses and counsel to strengthen the
scientific and technical basis for Agency decisions. In Fiscal Year 2002, the Board' s advice had a positive impact
on the production and use of science at the EPA with regard to a number of challenging issues. Board members
and consultants drafted key reports in the areas of risk assessment, benefits assessment, research planning, and
assessing and reporting ecological conditions.
The SAB Staff Office strengthened its internal capabilities and made the Board' s operations more transparent. It
implemented a new panel formation process and enhanced efforts to involve external stakeholders in the SAB' s
work to gain the benefits of their unique insights and perspectives.
As the EPA addresses tough environmental challenges in the year ahead, we will continue to look to the Science
Advisory Board for the expert advice and counsel so essential to the pursuit of our mission.
Christine Todd Whitman
U.S. EPA Administrator
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Introduction
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Background
Since 1978, when the Science
Advisory Board (SAB) was created
by Congress, the Board has provided
advice to the Agency to improve the
EEAs ability to make sound environ-
mental decisions. Congress created
the SAB to provide independent
advice and peer review to the EPAs
Administrator and to Congress on
the scientific and technical aspects
of environmental problems and
issues. Experts on the Board and
the EPA SAB Staff Office work to
produce advice that is technically
and scientifically sound, independ-
ent, balanced, and useful to the
Agency.
The SAB Executive Committee, the
leadership of the Board, set a goal for
the Board: to make a positive differ-
ence in the production and use of sci-
ence at the EPA.
In the Science Advisory Board
Strategic Plan (1998), the Executive
Committee stated that the Board's
mission is to: "Provide independent,
relevant advice on the scientific and
technical dimensions of the Agency's
actions to carry out its own mission
of protecting human health and
safeguarding the natural environ-
ment on which life depends."
To achieve that goal, the Board
focuses on technical issues, not
policy issues; risk assessment and
engineering issues, not risk man-
agement; the adequacy of the
scientific foundation on which an
Agency position (e.g., a regulatory
standard) is built, not the position
itself. The SAB recognizes the
Agency's need to make decisions on
environmental policy, risk manage-
ment, and regulations, but does not
advise the Agency on the merits of
those decisions. Instead it limits its
advice to the scientific and technical
underpinnings on which those deci-
sions rest. Where the Board's
advice does touch on policy issues,
it takes special care to note and
highlight those instances.
Science Advisory Board FY 2002
activities have included science
advice on topics where the EPA has
been at the crossroads, facing
choices about priorities for research
in environmental science and risk
management choices that will be
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Where SAB Advice Fits into Environmental Protection at the EPA
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EPA
Program
Offices
EPA
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DISCUSSION OF
PRIORITIES
by SAB Executive
Committee and
EPAs Cross-Agency
Science Policy
Project ideas
originated by SAB
Committees
AGENCY
DECISIONS
• Guidance
• Research and
scientific programs
Other Factors
Legal and institutional concerns
• Other information and
expert judgement
• Values
influenced by science. In risk assess-
ment projects, such as trichloroeth-
ylene, the Board has responded to
the need for highly visible reviews of
contentious scientific issues.
SAB Advice Process
The SAB develops advice in
response to Agency requests and in
response to original project ideas
developed by SAB Committees for
an Agency client. The SAB staff
works both with the Executive
Committee of the SAB and the
senior leadership of the EPA through
EPAs Science Policy Council to
choose the slate of activities the
Board will undertake.
The scope of the Board's work is
potentially as wide as all of the
scientific and technical issues associ-
ated with environmental problems.
It can involve advice on human
health risk assessment for a specific
chemical; advice on the guidelines
to be used for assessing risks to
human health in general or the risks
to children in particular; advice on
methodologies for assessing ecologi-
cal risks; advice on Agency draft
cost-benefit studies; evaluation of
engineering options for addressing
environmental problems; or advice
on the use of data and methods
from the social sciences to solve
these problems. As a result, the
work of the Board calls for experts
from a wide variety of scientific and
technical disciplines.
The Board provides several kinds of
written advice to the Agency. It
issues peer review reports of Agency
documents. It writes advisories,
when it has reviewed Agency
works-in-progress. It initiates com-
mentaries or more extensive original
reports on topics that it believes are
important to environmental protec-
tion. It provides the Agency an
opportunity for consultations at the
earliest stages of development of a
project to gain insights from inde-
pendent members and consultants.
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Finally, it hosts workshops on
important scientific issues, in which
the Board itself does not provide
advice but instead sponsors meet-
ings where the Agency can be
stimulated by the work of highly
qualified technical people.
The Board is, by law, a Federal
Advisory Committee that conducts
its business in public view and
benefits from public input during its
deliberations. Through these public
meetings, Agency positions—and
SAB science advice—are available
for critical examination on their
technical merits in an open forum.
Once the EPA receives the Board's
advice, the Agency then chooses
whether and how to factor the Board's
advice into decisions on regulations,
risk assessments, technical guidance,
and research programs. This
Accomplishments Report describes
some ways in which the Board has
had an impact on Agency decisions.
Science at the
Crossroads: Why the
SAB Matters Now
The EPA's decisions on tough envi-
ronmental challenges depend on
access to sound science. The EPA's
SAB helps to strengthen how the
Agency produces that science and
how the science is used. Because it
is a Federal Advisory Committee,
the Board gives the Agency the ben-
efit of different perspectives, differ-
ent experience, and different scien-
tific experience that can aid in
addressing present and future envi-
ronmental protection issues. The
SAB, as a scientific and technical
advisory committee, understands
the essence of science is knowledge
that is discussed, evaluated, and
challenged in a public forum. In FY
2002, the Board sought new and
more effective ways to provide pub-
lic input that will encourage the
highest quality science advice to be
delivered to the Agency. SAB is con-
tinuing that effort in the year ahead.
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ON TOUGH ENVIRONMENTAL CHALLENGES DEPEND
ON ACCESS TO CREDIBLE SCIENCE.
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People Behind the Advice
In FY 2002, the Board addressed a
wide range of topics that provided
different kinds of science advice to
the EPA. The number of SAB
members in any given year is flexible
and responds to the number of
experts needed to provide the EPA
with science advice. In FY 2002,
SAB consisted of 107 members
appointed by the Administrator for
two-year terms. Where additional
expertise is needed, the Board sup-
plements the knowledge, expertise,
and experience of its members with
consultants appointed by the SAB
Staff Director, experts from other
federal agencies (federal experts),
and experts serving on other EPA
Federal Advisory Committees
(liaisons). In FY 2002, 69 consult-
ants, two federal experts, and two
liaisons worked with the Board.
The advice provided by the SAB is
developed either by individuals
serving on ad hoc panels established
to address specific topics or by the
SAB's standing committees aug-
mented, if necessary, with special
expertise provided by SAB
consultants.
Whether they serve as members,
consultants, federal experts, or
liaisons, the scientists who develop
SAB advice constitute a distinguished
body of scientists, engineers, econo-
mists, and other social scientists who
are recognized experts in their
respective fields. These individuals
are drawn mainly from academia;
industry; federal, state, and tribal gov-
ernments; research institutes; and
environmental organizations
throughout the United States.
The SAB is the chartered Federal
Advisory Committee for eight stand-
ing committees, whose activities are
coordinated by the SAB Executive
Committee. These standing com-
mittees report to the Administrator
through the SAB's Executive
Committee. In addition, the chairs
of two separately chartered Federal
Advisory Committees, the Clean Air
Scientific Advisory Committee
(CASAC), and the Advisory Council
on Clean Air Compliance Analysis,
(the Council) are members of the
SAB Executive Committee. These
separately chartered committees
report directly to the Administrator.
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Coordination Within the SAB and with CASAC and the Council
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SAB EXECUTIVE COMMITTEE
Ivisory Council
an Clean Air
Compliance
lysis (Council)
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Dr. William H. Glaze, Chair,
SAB Executive Committee
Dr. William H. Glaze is a Professor in the
Department of Environmental and Biomolecular
Systems at the OGI School of Science and
Engineering of the Oregon Health and Science
University. He is also Professor Emeritus at the
University of North Carolina in Chapel Hill,
where he directed the campus-wide Carolina Environmental Program. From
} 988 to 2001, he served as Editor of the journal, "Environmental Science and
Technology," the highest rated publication of its type in the world. Since
January 2000, he has been Chair of the Executive Committee of the EPA SAB.
Previously, he was the first Chair of the SAB's Drinking Water Committee begin-
ning in 1 986.
Dr. Glaze received his B.S. degree in Chemistry from Southwestern University in
1 956. He received M.S. and Ph.D. degrees from the University of Wisconsin in
Madison in 1 958 and 1 960 and was a Robert A. Welch Post Doctoral Scholar at
Rice University. He is the recipient of numerous awards, which include the
Alexander von Humboldt Foundation Senior Science Award in 1997,
Newsmaker of the Year Award of the American Chemical Society in 2000, and
the Advanced Oxidation Technologies Award in 2001. His areas of research
interest include analytical methods for the determination of organic compounds
in water; ozone and advanced oxidation methods for water treatment and
global evaluation of drinking water treatment alternatives. He has been involved
in several initiatives related to sustainable environmental management and poli-
cy, including the interdependency between the U.S. and Mexico, the develop-
ment of the Green Chemistry Institute, drinking and wastewater infrastructure in
the U.S. and developing countries, future developments to minimize the impact
of the automobile, and alternatives to command-and-control regulatory policy.
SAB Executive
Committee
The SAB Executive Committee
provides leadership for the Board by
providing strategic advice and quali-
ty control. It sets the agenda and
works with the Staff Office to ensure
the highest standards. Since 2000,
Dr. William Glaze has chaired the
SAB Executive Committee.
SAB Staff Office
The activities of the Board's
members, consultants and federal
experts and liasons are supported
by the EPAs SAB Staff Office. In FY
2002, the long-standing SAB Staff
Director, Dr. Donald G. Barnes,
retired, and the Administrator
appointed Dr. Vanessa Vu as the
new Director of the SAB Staff Office.
Since Dr. Vu joined the SAB staff in
June 2002, she has worked with the
SAB staff to support projects under-
way, to strengthen staffing and
infrastructure in the office, and to
enhance staff coordination with the
Agency. Looking toward the future,
she held a strategic planning retreat
with the SAB staff in November
2002 to articulate the mission,
vision, and values that will guide
the Staff Office's work.
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Dr. Vanessa T. Vu, Director, SAB Staff Office
Dr. Vanessa T. Vu comes to the SAB Staff Office from EPAs Office of Science Coordination and Policy
within the Office of Prevention, Pesticides, and Toxic Substances, where she served as Director and
provided leadership for the management of FIFRA's Scientific Advisory Panel. From 1 998 to 2001 ,
she served as Associate Director for Health in EPAs National Center for Environmental Assessment
within the Office of Research and Development. She served as the Director of the Risk Assessment
! Division from 1 995 to 1 998 and the Deputy Director of the Health and Environmental Review
Division from 1 992 to 1 995 in EPAs Office of Pollution Prevention and Toxics.
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Dr. Vu received her B.A. degree in Biology and Chemistry from Case Western Reserve University in 1 973 and her Ph.D. in
Pharmacology from the George Washington University in 1 980. Prior to joining EPA, she held several academic positions
including a postdoctoral fellow at the Johns Hopkins University, Research Associate at the Vincent Lombardi Cancer Center,
and Staff Fellow at the National Cancer Institute. Dr. Vu has served on many advisory and expert panels within and outside
the EPA. She is the author or co-author of numerous research articles, EPA scientific reviews, and book chapters in
pharmacology, toxicology, and risk assessment. She has received many honors for her scientific, management, and
eadership accomplishments, including the Presidential Rank of Meritorious Senior Executive.
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WE MUTUALLY SUPPORT THE BOARD IN PROVIDING
INDEPENDENT. HIGH-QUALITY TECHNICAL AND SCIENTIFIC ADVICE TO THE AGENCY FOR
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Highlights from SAB
Advice in FY 2002
The EPA SAB's FY 2002 Annual
Staff Report provides a full description
of FY 2002 reports and activities.
This Accomplishments Report high-
lights only a few major projects for
FY 2002 to give a sense of their
wide range and potential impact on
the Agency. Because these reports
are so recent, the Board has not
received formal responses from the
EPA Administrator, but Agency senior
managers have provided preliminary
responses regarding the reports'
impact, and these responses are
included below.
The timeline on pages 14-15 presents
an even broader perspective of the
Board' s work and accomplishments.
It highlights reports from the recent
past (FY 1999-2002), where the
Board received formal responses
from the Agency or where Agency
managers have noted the impacts of
SAB advice on the production and
use of science at the EPA.
A look at the SAB Committee and
Panel Chairs who steered the major
projects highlighted in this section
gives a sense of the range of expert-
ise and experience of the scientists
who serve the Agency through the
Board.
1. A Framework for Assessing and
Reporting on Ecological Condition
(EPA-SAB-EPEC-02-009)
In this self-initiated report, the SAB
provided the Agency with a sample
conceptual framework to serve as a
guide for designing a system to
assess, and then report on ecologi-
cal condition at a local, regional, or
national scale. The sample frame-
work is intended as an organizing
tool to help the EPA decide what
ecological attributes to measure and
how to aggregate those measure-
ments to report more effectively on
the state of the nation's environment
and the improvements resulting
from Agency programs.
Preliminary Agency Reponse from
Dr. Peter Preus, Director, National
Center for Environmental
Research: "The report and the
recommended framework provides
a significant opportunity for the EPA
and our partners to improve both
the collection and use of ecological
information. The EPA has committed
to moving toward a results-based
management system. This will
require integrating indicators into
goals, milestones, and strategies,
and tracking our progress. The
report the SAB provided will help
the Agency to systematically identi-
fy the indicators and supporting
data that will be needed to achieve
our objectives.
The report has already demonstrated
its value as an important tool for the
Agency. The framework recom-
mended in the report was adopted
for describing the ecological condition
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of the Nation in the EPA's Report on
the Environment that will be
released in spring 2003. The use of
the framework in the Report on the
Environment has helped the EPA
and our partners to identify, assem-
ble, and report on ecological condi-
tion. The framework has also
helped us to identify gaps in both
information and knowledge."
2. Review of the Office of Solid
Waste's Study, Industrial Surface
Impoundments in the United States:
An EPA Science Advisory Report,
EPA-SAB-EEC-03-001
In this report, the SAB advised the
Agency on a study conducted to
assess human-health and ecological
risks associated with surface
impoundments used to manage
nonhazardous industrial waste. The
Agency will use the study results to
decide whether, and how, to apply
land disposal restrictions or take
other appropriate actions to address
risks found and any regulatory gaps
that may exist. The Board found
the Agency's report to be a major
advance in understanding the
nature of industrial surface
impoundments receiving non-
hazardous liquid wastes.
Dr. Terry Young, Senior Consulting
Scientist, Environmental Defense
Chair: Framework for Assessing and
Reporting on Ecological Condition
Dr. Terry Young is an independent consultant and
has managed projects for Environmental Defense
for more than twenty years. Her recent work
includes the design of a system that uses economic
incentives, including input pricing and tradable discharge permits, to control farm
pollution in California's San Joaquin Valley. Additional work includes the develop-
ment of ecological indicators to track management and restoration of ecologica
systems such as the San Francisco estuary. She has published on topics of
economic incentives for environmental protection, indicators of ecological integrity,
and market solutions for water pollution. Dr. Young received her B.S. in chemistry
at Yale University and her Ph.D. in Agricultural and Environmental Chemistry from
the University of California at Berkeley.
Preliminary Agency Response From
Dr. Michael Shapiro, Deputy
Assistant Administrator, Office of
Water, and Past Principal Deputy
Assistant Administrator, Office of
Solid Waste and Emergency
Response: "This report was prepared
at the request of the Office of Solid
Waste and Emergency Response
(OSWER) as a review of a
Congressionally mandated study that
characterized the risks associated
with thousands of federally unregulat-
ed surface impoundments used to
manage industrial waste. It is note-
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Dr. Byung Kim, Staff Technical
Specialist, Ford Motor Company
Chair: Solid Waste Surface
Impoundment Advisory Report
Dr. Byung R. Kim is Staff Technical Specialist in the
Physical and Environmental Sciences Department
of Ford Research Laboratory, Dearborn, Michigan,
and is a professional engineer. His current research
interest is in understanding various manufacturing emission issues (physical/
chemical/biological waste treatment processes and the overall environmenta
impact of manufacturing processes). He also has worked on the adsorption of
organics on activated carbon and water quality modeling. He served on the
advisory board for the National Institute of Environmental Health Superfund Basic
Research Program at the University of Cincinnati. He received a Richard R. Torrens
Award for editorial leadership from ASCE and two Willem Rudolfs Medals from
the Water Environment Federation for his publications in industrial wastes.
worthy that SAB's engagement in
this activity actually began at the out-
set of the effort when another panel
of the SAB consulted with OSWER
staff on the study design. Since the
study had to be conducted under
tight Congressional deadlines with
limited budget, the early engagement
by SAB was critical in developing an
approach that had the best chance to
address the policy issues associated
with the subject facilities. As a result
of that consultation, OSWER staff
chose a tiered approach to sampling
and analysis that allowed them to
focus resources on the types of facili-
ties that presented the greatest poten-
tial risk. In their review of the draft
study report, the SAB panel mem-
bers worked to understand the con-
text of the work and the pragmatic
judgments that had to be made in
executing the study within time and
budget constraints."
3. Review of Draft
Trichloroethylene Health Risk
Assessment: Synthesis and
Characterization,
EPA-SAB-EHC-03-002
In this peer review report, the SAB
reviewed a draft hazard assessment
for trichloroethylene (TCE), a
chemical significant for being a
nearly ubiquitous environmental
contaminant in both air and water,
being a common contaminant at
Superfund sites, and listed in many
federal statutes and regulations. It
also provided advice on several
important new areas in risk assess-
ment: 1) risk to children and other
susceptible populations;
2) cumulative risk; 3) examination
of multiple kinds of evidence,
including evidence about physiologi-
cal and molecular modes of action;
4) the assessment of the health risks
associated with the many metabo-
lites of TCE; 5) the use of biologically
based modeling; 6) the explicit
recognition and acknowledgment of
uncertainties in the risk analysis;
and 7) the consideration of multiple
data sets from animal and human
studies to derive cancer slope factors.
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Preliminary Agency Reponse from
Dr. George Alapas, Acting Director,
National Center for Environmental
Assessment: "The SAB recently
conducted a scientific peer review of
the EPA's draft Trichloroethylene
Health Risk Assessment: Synthesis
and Characterization. This draft risk
assessment includes a synthesis and
characterization of both noncancer
and cancer toxicity of trichloroethyl-
ene. The SAB's report provided a
clear and comprehensive peer review
of the EPAs draft assessment, and
the comments by the SAB will be
very helpful in improving the final
assessment. As recommended, the
EPA is currently revising the draft
assessment based on the advice
provided by the SAB as well as
comments received from the public."
4. Affordability Criteria for Small
Drinking Water Systems: An EPA
Science Advisory Board Report,
EPA-SAB-EEAC-03-004
This report represents the conclusions
and recommendations of the EPAs
SAB regarding the EPA affordability
criteria that determine whether
variances will be available to small
systems as they implement maxi-
mum contaminant level regulations
under the Safe Drinking Water Act.
The Agency asked the SAB for
Dr. Henry Anderson, Chief Medical Officer,
Wisconsin Division of Public Health
Chair: Trichloroethylene Health
Risk Assessment
Dr. Anderson holds positions as the State
Environmental and Occupational Disease
Epidemiologist in the Wisconsin Department of
Health and Social Services, Chief Medical Officer in
the Wisconsin Division of Public Health, and adjunct Professorship at the
University of Wisconsin - Madison, Department of Population Health, and the
University of Wisconsin Institute for Environmental Studies, Center for Human
Studies. His expertise includes public health; preventive, environmental and
occupational medicine; respiratory diseases; epidemiology; human health risk
assessment; and risk communication. Active research interests include: environmen-
tal health indicators and disease surveillance, childhood asthma, lead poisoning,
reproductive and endocrine health hazards of sport fish consumption, arsenic in
drinking water, chemical and nuclear terrorism, occupational and environmenta
respiratory disease, occupational fatalities, and occupational injuries to youth.
He was a founding member of the Agency for Toxic Substances and Disease
Registry (ATSDR) Board of Scientific Councilors (1 988-1 992). He served on
National Academy of Sciences/Institute of Medicine (NAS/IOM) committees that
developed the reports "Injury in America" and "Nursing, Health & Environment."
He serves on the Presidential Advisory Board on Radiation Worker Compensation,
the Hanford Human Health Effects Subcommittee, and the Rocky Flats Advisory
Committee for the Beryllium Program. He serves on the Centers for Disease
Control and Prevention (CDC), National Center for Environmental Health,
Director's Advisory Committee. He is a fellow of the Collegium Ramazzini and the
American Association for the Advancement of Science. He is associate editor of
the "American Journal of Industrial Medicine" and serves on the editorial board of
"Cancer Prevention International. "
Dr. Anderson received his MD degree in 1 972 from the University of Wisconsin,
Madison. He was certified in 1 977 by the American Board of Preventive Medicine
with a sub-specialty in occupational and environmental medicine and in 1 983
became a fellow of the American College of Epidemiology.
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The EPA SAB—Meeting Challeng
for Credible Science
Impacts of Recent Reports FY 1999-2002
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Implementation of the
Agency-Wide Quality System
(E PA-S AB-E EC-LTR-99-002)
"...The Board's support in
validating the concept of quality
systems for environmental data
systems and tools to be used for
assuring data quality provide the
backbone of the Agency's infor-
mation quality guidelines."
Ms. Nancy Wentworth,
Director, Quality Staff,
Office of Environmental
Information
National Human Exposure Assessment
(NHEXAS) Pilot Studies (EPA-SAB-IHEC-
ADV-99-004)
Review of the Draft Strategic Plan for the
Analysis of National Human Exposure
(NHEXAS) Pilot Study Data
(EPA-SAB-IHEC-00-01 8)
"The SAB advice and review of ORD plans helped
ORD set its directions for analysis of this rich data
source needed to address Agency requirements
associated with the Food Quality Protection Act
and the Agency's mission to protect human
health." Dr. Gary Foley, Director, National
Exposure Research Laboratory, Office
of Research and Development
Review of the Draft Document:
Airborne Particulate Matter:
Research Strategy, (EPA-SAB-
CASAC-LTR-99-004)
"The work over the past five or six years
in the area of particulate matter is truly
striking...Through advice from the SAB
and from the National Research Council,
a strong plan was put together."
Dr. Paul Gilman, EPA Science
Advisor and Assistant
Administrator, Office of
Research and Development
Advisory on the Charter for the
Council on Regulatory
Environmental Modeling (CREM)
(EPA-SAB-EC-ADV-99-009)
"EPA has been embarking on a num-
ber of initiatives to 'revitalize' the
Council for Regulatory Environmental
Modeling (CREM)." Dr. Gary Foley,
Director, National Exposure
Research Laboratory, Office of
Research and Development
EPA Guidelines for Preparing
Economic Analysis (EPA-SAB-
EEAC-99-020)
"The Guidelines had to reflect the
very latest advancements of econom-
ics, but be practical enough to be use-
ful to the economists at EPA. EEAC
worked with us to develop the best
overall design of the Guidelines....
These Guidelines continue to govern
the conduct of economic analysis in
the agency." Dr. Albert
McGartland, Director,
National Center for
Environmental Economics,
Office of Policy Economics
and Innovation
Improved Science-
Based Environmental
Stakeholder Processes
(EPA-SAB-EC-COM-01 -006]
"The Agency's Final Public
Involvement Policy, scheduled for
release this spring, will reflect many
of the concerns raised in your report
and will recognize the role that
sound science can and must play in
EPA's decision-making processes."
Gov. Christine Todd
Whitman, Administrator
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NATA-Evaluating the
National-Scale Air Toxics
Assessment 1996 Data -
An SAB Advisory
EPA-SAB-EC-ADV-02-001
"EPA intends to act on all
of the Panel' s near-term
recommendations, incorporating
them either directly into the
publication of 1996 NATA
results on the Internet or into
short-term studies whose
results would be published in
technical reports and linked to
the NATA web site."
Gov. Christine Todd
Whitman, Administrator
Monitored Natural Attenuation: US
EPA Research Program - An EPA
Science Advisory Board Review
(EPA-SAB-EEC-01-004)
"I am pleased that the SAB found the
work to be scientifically sound and that it
has improved the understanding of
Monitored National Attenuation (MNA)
Research Program and its applications."
Gov. Christine Todd Whitman,
Administrator
Arsenic Rule Benefits Analysis: An
SAB Review (EPA-SAB-EC-01-008]
"The final report...contributed greatly to
our better understanding of the many
issues that underlie the arsenic in drink-
ing water regulation and played a key
role in the Agency's decision on the final
arsenic standard." Gov. Christine
Todd Whitman, Administrator
Review of the Southeastern
Ecological Framework: An EPA
Science Advisory Board Report
(EPA-SAB-EPEC-LTR-02-002)
"Integration of various regional
assessment approaches and applying
the SAB Framework for Assessing
and Reporting on Ecological
Condition are important next steps
now under review by the Critical
Ecosystems Steering Committee."
Gov. Christine Todd
Whitman, Administrator
Review of the Draft Analytical
Plan for EPA's Second
Prospective Analysis - Benefits
and Costs of the Clean Air Act
1 990-2020 (EPA-SAB-COUN-
CIL-ADV-01-004]
"The Council's efforts provide a
balanced and thoughtful review of
the EPA's initial proposals for the
design of the study and offer many
creative solutions to the challenges
the Agency will face in its imple-
mentation." Gov. Christine
Todd Whitman,
Administrator
Review of the Agency's Draft Continuous
Monitoring Implementation Plan: A
Review by the Clean Air Scientific Advisory
Committee (EPA-SAB-CASAC-LTR-02-001 ]
"...EPA is already taking steps to incorporate the
Subcommittee's comments and recommenda-
tions into the next iteration of our Continuous
Monitoring Implementation Plan, and we will
look forward to enhancing the ambient air moni-
toring network with these improved technolo-
gies." Gov. Christine Todd Whitman,
Administrator
N
FY 2003 Presidential Science and
Technology Budget Request for the
Environmental Protection Agency; An
SAB Review (EPA-SAB-RSAC-02-007)
"...EPA's continued emphasis on science
and technology reflect recognition of the
importance of maintaining a strong scien-
tific foundation upon which decisions are
made." Gov. Christine Todd
Whitman, Administrator
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Dr. Robert Stavins, Albert Pratt
Professor of Business and Government,
John F. Kennedy School of Government,
Harvard University
Chair: Affordability Criteria for Small
Drinking Water Systems Report
i Dr. Robert N. Stavins also serves as Director of the
Environmental Economics Program at Harvard
University. He is a University Fellow of Resources for the Future, Past Chairman of
the Environmental Economics Advisory Committee of the EPAs SAB, Director of
the University-wide Environmental Economics Program at Harvard University; and
a member of the EPAs Clean Air Act Advisory Committee, the Intergovernmenta
Panel on Climate Change (IPCC), the Board of Directors of the Robert and Renee
Belfer Center for Science and International Affairs, the Executive Committee of the
Harvard University Committee on Environment (UCE), and the Board of
Academic Advisors of the AEI-Brookings Joint Center for Regulatory Studies.
Dr. Stavins' research has focused on diverse areas of environmental economics
and policy, including examinations of: policy instrument choice under
uncertainty, competitiveness effects of regulation, design and implementation of
market-based policy instruments, diffusion of pollution-control technologies, and
depletion of forested wetlands. His current research includes analyses of:
technology innovation, environmental benefit valuation, political economy of
policy instrument choice, and econometric estimation of carbon sequestration
costs. Professor Stavins directed Project 88, a bi-partisan effort co-chaired by
former Senator Timothy Wirth and the late Senator John Heinz, to develop
innovative approaches to environmental and resource problems. Prior to coming
to Harvard, Dr. Stavins was a Staff Economist at the Environmental Defense Fund,
and before that, he managed irrigation development in the Middle East and
spent four years working in agricultural extension in West Africa as a Peace
Corps volunteer.
advice on: 1) the EPA's basic approach
to determining affordability for small
systems (i.e., comparing average
compliance costs with an expendi-
ture margin); 2) components of the
affordability determination method
(i.e., use of median household
income, alternatives to the 2.5%
affordability threshold, calculation of
the expenditure baseline); 3) the
application, focus and/or definition
of affordability (i.e., the use of
separate national level affordability
criteria for ground water vs. surface
water systems; the need for making
affordable technology determinations
on a regional rather than a national
basis); and 4) whether financial
assistance should be considered in
EPA's national level affordability
criteria.
The report presents the SAB's find-
ings and recommendations on the
Agency's charge questions. The
report notes that the Agency's basic
approach is justified on the basis of
equity and efficiency considerations,
as well as considerations of adminis-
trative practicality. The SAB also
addressed limitations of the basic
approach and suggested the EPA
modify it where appropriate and pos-
sible. They encouraged the Agency
to consider options of system consoli-
dation when analyzing the nature
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and duration of any standards relax-
ation and noted that the use of a
national trigger as a screening device
suggests the adoption of a fairly low
affordability threshold. The SAB
encouraged the EPA to develop clear
and formal guidelines about when
variances should be granted at the
local level and to conduct research
into possible mechanisms for achiev-
ing greater equity in distribution of
water costs to individuals.
Preliminary Agency Response from
Dr. Albert McGartland, Director,
National Center for Environmental
Economics: "Throughout the delib-
erations on the Affordability
Criterion, the SAB's Environmental
Economics Advisory Committee was
careful to draw distinctions between
matters of economic science and
policy decisions. It was a triumph
of the Committee that they succeeded
in reviewing and suggesting
improvements to the economic
measurement of affordability with-
out stepping on the policy button.
As a result, policy makers will be in
a better position to design an afford-
ability criterion with appropriate
economic parameters consistent
with their policy goals."
Dr. A. Myrick Freeman, Professor,
Bowdoin College
Chair: UST and RCRA Program Benefits,
Costs and Impacts Assessment
Dr. A. Myrick Freeman is the William D. Shipman
Research Professor of Economics at Bowdoin
i College, where he has been on the faculty since
1 965 and has served as Chair of the Economics
Department as well as Director of the Environmental Studies Program. Dr.
Freeman's principal interests are in the areas of applied welfare economics,
benefit-cost analysis, and risk management as applied to the development of
models and techniques for estimating the welfare effects of environmental
changes, such as the benefits of controlling pollution and the damages to natura
5. Underground Storage Tanks
(UST) Cleanup & Resource
Conservation & Recovery Act
(RCRA) Subtitle C Program
Benefits, Costs, & Impacts
Assessments: An SAB Advisory,
EPA-SAB-EC-ADV-03-001
Through this report, the SAB
advised the Agency on methods
and approaches for measuring
benefits and costs for the Agency's
Underground Storage Tank and
Resource Conservation and
Recovery Act (RCRA) Hazardous
Waste Program.
The Panel offered advice on measur-
ing benefits, costs and impacts in
terms of human health benefits,
ecological benefits, indicators,
avoided costs, the property value
approach, as well as alternative
approaches. Other topics touched
upon dealt with distributional
impacts, including environmental
justice, intragenerational impacts,
economic impacts, risk tradeoffs,
and intergenerational equity.
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Dr. Valerie Thomas, Research Scientist,
Princeton University
Chair: Metals Action Plan Report
11 • Dr. Valerie Thomas is a Research Scientist at the
Princeton Environmental institute at Princeton
^^^^^^^^f University. Dr. Thomas received her Ph.D. in
i theoretical physics from Cornell University and was
a post-doctoral Research Fellow at the
Department of Engineering and Public Policy at Carnegie Mellon University.
Her research is in the areas of Industrial Ecology and Environmental Policy.
Recent research topics include mercury exposure, dioxin sources, the economic
demand impacts of second-hand markets, electronics for product recycling,
environmental policy in the former Soviet Union, and ethanol as a gasoline lead
replacement in Africa. She is co-author of the book "Industrial Ecology and
Global Change," (Cambridge University Press, 1 994). She is a Fellow of the
American Physical Society. She will be vice-chair of the Gordon Conference on
Industrial Ecology in 2004 and chair in 2006.
Preliminary Agency Reponse from
Dr. Michael Shapiro, Deputy
Assistant Administrator, Office of
Water, and Past Principal Deputy
Assistant Administrator, Office of
Solid Waste and Emergency
Response: "This panel was con-
vened in 2002 to review two docu-
ments covering methodologies for
evaluating costs, benefits and related
impacts of programs under the
Resource Conservation and Recovery
Act (RCRA) Hazardous Waste
Program and the Underground
Storage Tank (UST) Program. The
panel suggested a revised framework
" THE SCOPE OF THE BOARD'S WORK is POTENTIALLY
AS WIDE AS ALL OF THE SCIENTIFIC AND TECHNICAL ISSUES
ASSOCIATED WITH ENVIRONMENTAL PROBLEMS."
for the proposed analyses which the
Office of Solid Waste and Emergency
Response (OSWER) believes will pro-
vide a more rigorous and credible
structure while still meeting the
Office's primary objectives in under-
taking the studies. The panel also
identified broader analytical issues
that need to be considered across
Agency programs in evaluating
human health and ecological bene-
fits. OSWER staff were particularly
pleased with the extensive interaction
with the panel afforded by the
| process."
6. Review of Metals Action Plan:
An EPA Science Advisory Report,
EPA-SAB-EC-LTR-03-001
The Metals Assessment Panel of the
EPA SAB reviewed the EPAs Metals
Action Plan for development of a
Framework for Metals Risk
Assessment and a Guidance for
Characterization and Ranking of
Metals. The Plan identifies the
Agency's view of the key scientific
issues important for assessing the
hazards and risks of metals in gen-
eral. This review addresses the
broad scientific issues underlying
the assessment of metals hazards
and risks. Overall, the Panel agreed
that metals should be assessed dif-
ferently from organic pollutants in a
-------
number of contexts. The Panel also
agreed that the issues of chemical
speciation, bioavailability, bioaccu-
mulation, and toxicity are key issues
in assessing the hazards of metals
and that by considering the scientific
issues broadly in development of an
overall framework, the EPA can
develop a scientific foundation to
support appropriate simplifications
in particular applications.
Preliminary Agency Response from
Dr. William Wood, Director, Risk
Assessment Forum Staff: "The
Agency appreciates the efforts of the
SAB in conducting the recent review
of the Agency's Action Plan for
development of a Framework for
Metals Assessment and a Guidance
for Characterization and Ranking of
Metals. The SAB's Metals Assessment
Panel provided review comments
that will make a fundamental and
positive contribution to the future
assessment practices of the Agency
regarding metals. Since this review
marked the initiation of activities,
the Agency looks forward to a con-
tinuing dialogue with the SAB on
these challenging issues and intends
to submit for SAB review the
Framework for Metals Assessment
and the Guidance for Characterization
and Ranking Metals in FY 2004."
/
n
Dr. Janet Johnson, Senior
Technical Advisor, MFC, Inc.
Chair: Multi-Agency Radiological
Laboratory Analytical Protocols Manual
Dr. Janet Johnson is currently employed at MFG,
Inc. in Fort Collins, CO, as a Senior Radiation
! Scientist with expertise in health physics, chemistry,
and environmental health. She is a certified indus-
trial hygienist (CIH, radiological aspects) in the comprehensive practice of health
physics by the American Board of Health Physics. She serves on the Governor's
(Colorado) Radiation Advisory Committee since 1 988 as well as the Governor's
Rocky Flats Scientific Panel on Monitoring, the Colorado Hazardous Waste
Commission. She also serves on the National Academy of Sciences Committee
on Low-Level Radioactive Waste Siting in New York State (1 993 to the present)
and is a Fellow of the Health Physics Society.
Dr. Johnson has broad-based consulting experience dealing with such topics as
nuclear safety and assessment of radiation risks. Her training includes a B.S. in
Chemistry from the University of Massachusetts, an M.S. in Health Physics (as an
AFC Health Physics Fellow) from the University of Rochester, and a Ph.D. in
Microbiology and Environmental Health from Colorado State University.
7. Multi-Agency Radiological
Laboratory Analytical Protocols
(MARLAP) Manual: An SAB Report
(Draft Report being developed by
the Radiation Advisory Committee)
The MARLAP Review Panel
reviewed technical aspects of a draft
Multi-agency Radiological Laboratory
Analytical Protocols (MARLAP)
Manual dated August 2001. This doc-
ument was developed collaboratively
by seven federal agencies, depart-
ments, and commissions having
authority for regulating radioactive
materials, and two states. The Panel
found that MARLAP effectively
addresses the need for a nationally
consistent, performance-based
approach for planning, implementing,
and assessing radioanalytical meas-
urements to address regulatory
concerns. The Panel made recom-
mendations for reorganizing and
editing the MARLAP manual, and
for training persons who will use it.
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Preliminary Agency Response
from Ms. Elizabeth Cotsworth,
Director, Office of Radiation and
Indoor Air: "In a recently released
draft report, the SAB provided peer
review of the Multi-Agency
Radiation Laboratory Analytical
Protocols (MARLAP) document, a
technical guidance manual on
detecting radionuclides for project
managers and radioanalytical
laboratories. The guidance will
allow the EPA clean-up programs
and six other federal agencies to
benefit from detection methods that
translate into meaningful measures
of exposure to radiation risk. It
provides a model for how multiple
agencies can benefit in a coordinated
way from practical scientific advice.
The advice itself and the multi-
agency coordination effort may have
future significance for homeland
security. The multi-agency team
that developed the MARLAP also
benefitted from the SAB's compre-
hensive review and interactions the
team had with the SAB's Radiation
Advisory Committee."
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SAB Information
Reaches Beyond the
Although the Board's purpose is to
provide advice to the Agency, the
demand for advice generated by the
SAB isn't limited to the EPA or even
to the United States alone. Analysis
of the use of the SAB web site
(vrvrvr.epa.gov/sab) shows that
both commercial and non-EPA gov-
ernmental organizations access the
site more than all of the EPA's offices
combined. Thus, while the SAB's mis-
sion is to advise the EPA on its science,
many customers for SAB information
are from outside the Agency.
In addition, SAB information is also
requested from users around the
world. About seven percent of the
total pages requested are from non-
US, domains, with European sites
the largest customers followed by
Asia and the Americas. Therefore,
the SAB has the potential for world-
wide impact by making information
products available around the world.
Selected SAB Web Page Statistics for Nov. 1-Nov. 30, 2002
Originating Domain of Request
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Improving the Process for
Developing SAB1s Advice
In FY 2002, the SAB Staff Office
introduced new processes for forming
advisory panels, reviewing informa-
tion to make decisions about conflict
of interest and balance of viewpoints,
working with stakeholders, and
coordinating with EPA clients.
With the advice of the SAB
Executive Committee's Policies and
Procedures Subcommittee, the Staff
Office implemented a new panel
formation process to help the Board
provide high-quality advice while
better meeting the requirements of
the Ethics in Government Act and
the Federal Advisory Committee Act
and improving transparency so the
public can understand and partici-
pate in the SAB panel formation
process. The SAB Staff Office
designed and implemented, with
public input, a new four-step panel
formation process and a new
Confidential Financial Disclosure
Form for Special Government
Employees Serving on Federal
Advisory Committees at EPA. It also
developed and implemented new
CD-ROM-based ethics training for all
SAB members and consultants.
These innovations have improved
how the SAB staff gather and evalu-
ate information about prospective
panel members' potential conflicts
of interests and how the SAB staff
organize panels to assure balanced
points of view. These processes
have set new standards for peer
review and operations of Federal
Advisory Committees at the EPA and
across the federal government. The
new panel formation process is
described in an Overview of the
Panel Formation Process at the
Environmental Protection Agency
SAB and is outlined on the next page.
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Stages in Panel Formation
KICKOFF
The SAB staff works with
the Agency and the SAB
leadership to understand
"What expertise is needed
to address the charge?"
WIDECAST
The SAB staff asks: "Wh
should be considered fc
the panel?" The staff
solicits nominations fror
Dnsultants and the
SHORT LIST
The SAB staff works witr
SAB leadership to
determine: "Which
es should we
Dnsider in great
• service on the
PANEL SELECTION
he SAB staff determines
and documents: 'Who
/ill serve on the panel?"
* The staff gathers additional information about the candidates (including confidential information from the
candidates about financial conflict of interest). They also ask the public for information that will help during the Panel
Selection Phase.
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The Board also began a series of
regular meetings with stakeholders
on public involvement in the SAB
Advisory Board activities. In a
Federal Register Notice, it invited
participants to attend a public session
on September 26, 2002, or to sub-
mit written public comments on
selected topics for improvements in
SAB policies and procedures. The
purpose of the session on September
26, 2002, was to discuss two topics:
1) improved public involvement in
SAB public meetings and in devel-
opment of SAB reports, and 2)
improvement of the SAB's public
access web site. Much of the discus-
sion also concerned the Board's new
panel formation process and the
need for transparency in forming
panels. The SAB Staff Office
summarized the public session as a
Stakeholder Meeting Report, posted
it on the SAB web site, and plans to
consider these concerns and sugges-
tions as it develops guidance and
plans for the Staff Office in its
support of the Board.
In FY 2002, the EPA Staff Office
worked to improve board processes
with input from a cross-agency
group of Agency senior managers—
the Agency's Science Policy Council—
and with leadership of the National
Academy of Sciences and National
Research Council.
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Activities at the Crossroads:
Outlook for FY 2003—Change
and Opportunities
Continuing to
Improve the Process
for Developing Advice
The SAB Staff Office plans to
continue its efforts to strengthen
opportunities for public involvement
in Board processes. A major goal is
continued improvement in the
Board's panel formation process,
with more consistency and better
communication with the public. In
addition, the Staff Office is planning
to develop guidance for panel chair-
persons, members of panels, SAB
staff, Agency staff, and members of
the public to clarify their roles and
the role of public involvement in SAB
reports and meetings. It foresees
continued improvement in the SAB
public access web site, so that users
will have information and tools nec-
essary to interact effectively with the
Board and the SAB Staff Office.
The Staff Office plans to hold semi-
annual meetings with members of
the public in the spring and fall of
2003 to hear concerns and sugges-
tions for additional improvements in
SAB policies and procedures.
Restructuring
the Board
An additional major effort of the
Board for FY 2003 complements
the project work of the members
and consultants that will result in
advice to the Agency in new areas
and Staff Office efforts to further
improve policies and procedures. A
subcommittee of the SAB Executive
Committee was established in
October 2002 to examine whether
the current structure and size of the
Board enable the Board's keeping
pace with and, even more impor-
tantly, anticipating the scientific and
technical issues facing the Agency.
Photo by Steve Delaney, EPA Photographer
The Chair of the SAB Executive
Committee, Dr. William Glaze, chairs
the subcommittee, and he is working
with the SAB staff to solicit input
regarding the restructuring effort
from SAB members and consult-
ants, EPA staff, and interested
members of the public. His initial
thoughts on the restructuring effort
and its importance follow.
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The SAB: A Grand
Tradition and a
Great Future
Since 1978, the EPA Science Advisory
Board has arguably been the most
effective science advisory board in the
federal government. All who are
familiar with the Board know that it has
made many contributions to helping the
Agency maintain a high level of science
in the decisions it has made, the
regulations it has promulgated, and the
programs it has established. Now the
SAB shares with the Agency new chal-
lenges, and it is appropriate for us to ask:
Can we do our job even more effectively?
Since I became involved with the SAB in
the late 1980s, I have shared with many
of my colleagues a deep respect for the
SAB staff who do its work on a day-to-
day basis and the many fine scientists
who contribute to its panels and the
standing committees as a public service.
This is one aspect of the SAB that I
know will never change, and whatever
we do in the future, we must continue to
find and retain the best people for these
positions. We must admit, however, that
the world is changing and if we wish to
protect it, we too must change.
What are these changes and what do
they portend for the way the SAB does
its business? The first I want to mention
is really not a change; it is a realization
that all environmental problems are
much more complex than we acknowl-
edged in the past. In the early days of
environmental protection, it was under-
standable for us to focus on the pollution
that was apparent to anyone; to arrange
our programs around media: air, water,
and soil; to focus on single compounds
rather than the ubiquitous mixtures
around us; or to treat human health and
ecological health as if they were unrelated.
The intervening years have shown us
that this strategy is neither scientifically
defensible nor always conducive to good
policy making. At the most general level
the environment and public health have
to be understood as a system, and we
must always be aware of links between
its various compartments as we try to
make decisions to protect it. Dealing
with this through a systems approach is
one of our challenges, one that we must
help the Agency deal with.
Fortunately, science can provide us with
the ways to deal with these complex
systems; but this raises another challenge
for the SAB. As any science grows more
deeply specialized, it becomes increas-
ingly difficult for a non-specialist to
understand, even one grounded in the
basics. New science makes the work of
the Agency more credible in principle,
but how does the SAB face the challenge
of reviewing this work of increasing
depth and complexity? There is really
only one solution for the SAB: we simply
must convince the best people from all
of the important research areas to serve
as expert reviewers if we are to give the
Agency the best advice. Is the current
way we do business in the SAB accom-
plishing this goal? If not, we must find a
better way.
Another major development in environ-
mental protection that is reflected on the
SAB is this: we have come to understand
that environmental protection is not only
an enterprise of the physical, biological,
chemical, and engineering sciences. For
environmental decisions to be made and
implemented effectively we must bring
the economics and the social and
behavioral sciences into the process
sooner and more effectively. We must
take into account how people make their
decisions; how they value protection of
themselves, endangered species, and
ecosystems; and how environmental
protection fits into the entire regime of
economic and social development. We
must acknowledge that the study of
these and other human characteristics is
a sophisticated scholarly enterprise that
must be factored into our work. Of
course, wise heads in the Agency and
the SAB knew this all along, but too
often our narrow professional focus
causes us to omit the very factors that
might make our work more effective.
Finally, in the future we must assist the
Agency in anticipating the problems of
the future and how the Agency might
address them, often with programs that
go beyond command and control. For
example, we might help develop a
better assessment of complex topics
such as the effects of climate change on
ecosystems, which will probably be rec-
tified by education and voluntary
actions rather than regulations. We
should also help the Agency develop
ways to assess the state of the environ-
ment and through careful analysis
suggest how this type of assessment
can guide future Agency program
development. And finally, we must
assist the Agency to recognize, antici-
pate and respond to new challenges that
are not anticipated at this time. The
SAB, therefore, must be an agile and
responsive organization while continuing
its call for the very highest standards in
its work and its reviews.
William H. Glaze, Ph.D.
Chair, SAB Executive Committee
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Upcoming Science
Advice Activities:
To develop an agenda for FY 2003,
the SAB Staff Office coordinated dis-
cussions with the Agency's Science
Policy Council and the SAB
Executive Committee. At the start of
the fiscal year, the project list that
resulted included: 25 peer review
projects, three advisories, eight
consultations, and two workshops or
self-initiated projects. Nine of these
projects involve multi-disciplinary or
multi-media science issues and will
be undertaken by special panels of
the SAB Executive Committee.
Charge to the Special Panel on 'Valuing the Protection of
Ecological Systems and Services":
Explore alternative approaches (e.g., benefit-cost analysis, ecological analy-
sis, and the analysis of public concerns and values) in terms of the sound-
ness and reliability of the methods involved, the current evidentiary base
associated with each, data gaps, and potential contributions to decision
making.
The work the Board will actually
undertake depends in great part on
the Agency's priorities and readiness
to receive SAB advice or undertake
SAB review, so the annual "operating
plan" of the Board is subject to
change.
Based on conversations with Agency
leadership, the Board foresees
important future work in modeling,
data quality, social sciences,
ecological issues, and new
approaches to toxicology that inte-
grate computational sciences and
genomics, as well as peer review of
selected chemicals and significant
issues related to risk assessment.
One planned activity for FY 2003 is a
project initiated by the SAB Executive
Committee: "Valuing the Protection
of Ecological Systems and Services."
The project will be a multi-year effort,
developed in response to Agency-
wide issues the Board has addressed
over many years: the need to high-
light the importance of the sciences
supporting ecological protection and
the need to characterize as fully as
possible the benefits of protecting
ecological systems and services. The
SAB Executive Committee envisions
the panel as being multi-disciplinary
— bringing together economists,
ecologists, decision scientists,
-------
engineers, and other kinds of social
scientists to work in close partnership
with the Agency to develop advice for
improving current practices for
assessing the value of protecting
ecological systems and services, and
to identify the most valuable research
opportunities in this area.
Looking Ahead
and Reaching Out
The Board's priorities are to provide
independent advice on priority topics
as requested by EPA offices and to
address emerging science issues of
importance to the Agency. To
improve how it provides that advice,
the Board and the Staff Office con-
tinue to strengthen the "infrastruc-
ture " of the Board through possible
restructuring efforts and through
strategies to recruit and retain the
best and diverse talents for the
Board. Other priorities include
improving policies and procedures
and enhancing communication both
within the Agency and with
members of the public so that the
work of the Board can be better
understood and the Board can better
serve needs for science advice to
improve environmental protection.
The SAB staff and the leadership
of the Board seek the public's
information and insights on
upcoming SAB advisory topics and
on opportunities to improve policies
and procedures at the Board. They
are also seeking future members of
the Board, individuals with the
technical knowledge, experience,
and expertise willing to work with
others to provide science advice to
the Agency, so that the work and
tradition of the Board may continue.
NOW THE SAB SHARES WITH THE AGENCY NEW
CHALLENGES, AND IT IS APPROPRIATE FOR US TO ASK:
CAN WE DO OUR JOB EVEN MORE EFFECTIVELY?
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27
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Protection Aeenc\
EPA Science Advison
Board (1400A)
EPA-SAB-03-OC
March 2003
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