United States Science Advisory EPA-SAB-EC-95-0Q8
Environmental Protection Board October 1994
Agency
SEPA The Science Advisory
Board: What's Next?
Report of the SAB Reinvention
Committee
The Sciasee Advisory Board:
Whavs Next?
Report of the SAB
Reinvention Commiaee
SCIENCE
ADVISORY
BOARD
AGENCY
INPUT
PUBLIC
INPUT
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EPA-SAB-EC-95-008
October 1994
The Science Advisory Board: What's Next?
Report of the SAB Reinvention Committee
Science Advisory Board
Washington, DC 20460
Printed on Recycled Paper
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Notice
This report has been written as a part of the internal operations of the Science Advisory Board
(SAB), a public advisory group providing extramural scientific, engineering, and economic advice
to the Administrator of the U.S. Environmental Protection Agency (EPA). This report has not been
reviewed for approval by the Agency; and hence, the contents of the report do not necessarily
represent the views and policies of the Agency or other agencies in the Federal government.
Acknowledgment
This study has benefited from the contributions of hundreds of people across the country. In
contrast to most SAB efforts, the reinvention report has drawn upon the work, insights, and wisdom
of SAB members and consultants, SAB staff, Agency headquarters personnel, Agency laboratory
personnel, former Agency leaders, leaders in other agencies, and scores of members of the
public—who are the ultimate and most important customers of the SAB.
We hope that we have been a faithful steward of the input from so many people and that the
SAB will be a demonstrably better institution because of what they have done.
The Reinvention Committee
October 1994
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Abstract
This report is the SAB's second self-study, a sequel to its Mission and Functioning Report of
1989. With a new SAB chair, a new Administrator, and a continually changing Board, it is both
appropriate and instructive to consider "reinventing the SAB" at this time.
As background for this study, the Board received input from more than 100 people, including
Agency political appointees (past and present), Agency personnel (from managers to bench
scientists), Board members, representatives of other agencies, and members of the public.
The main substance of the report is captured in findings and recommendations related to eight
SAB topics: mission, function, structure, selection of projects, timeliness, membership,
inter-committee and inter-advisory group interactions, and communications.
The major conclusions have much in common with the earlier report:
a. The SAB works and makes a difference.
b. The SAB continually responds to changing conditions in an evolutionary, not revolutionary, way.
c. The SAB's effectiveness is directly tied to its real and perceived independence from the Agency.
d. The SAB can serve the Agency in a number of different ways:
1) Advising role; cf., consultations and advisories
2) Rigorous peer review role; cf., reports
3) Self-initiated activities; cf., commentaries
e. There is room for continual improvement, especially in the area of timeliness, membership, and communications.
KEYWORDS; U.S. EPA, Science Advisory Board, SAB, advisory
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Science Advisory Board
Reinvention Committee
Chair
Dr. Genevieve Matanoski
School of Hygiene and Public Health
The Johns Hopkins University
Baltimore, MD
Members
Dr. Paul Deisfer
Austin, TX
Dr. Margaret Kripke
Department Immunology
M.D. Anderson Cancer Center
Houston, TX
Dr. Morton Lfppmann
Institute of Environmental Medicine
New York University
Tuxedo, NY
Dr. Raymond Loehr
Department of Civil Engineering
University of Texas
Austin, TX
Dr. EHen Siibergeld
Department of Epidemiology
University of Maryland
Baltimore, MD
Consultant
Dr. Sheiia Jasanoff
Department of Science and Technology
Cornell University
Ithaca, NY
Designated Federal Official
Dr. Donald Barnes, SAB Staff Director
SAB Staff Support
Randall Bond
Janice Cuevas
Manuel Gomez
Yvette Hellyer, on detail from the Office of Pollution Prevention and Toxics (OPPT)
Jason Holstine, summer intern from Ohio State University
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Foreword
The SAB is fast approaching completion of its second decade of service to EPA, the Congress,
and the public. During this time, the SAB has served as a valuable resource for providing advice
to EPA in the Agency's efforts to generate and use sound scientific information as the basis for action
to protect public health and the environment. Given the vast scope ol Agency interests arid
responsibilities, the SAB continually faces challenging opportunities.
Therefore, it is important that the Board step aside periodically and take slock of the job that it
is doing and seek ways in which It can do that job better.
In that spirit—the search for continuing improvement—the SAB undertook its second self-study
early in 1994. We reviewed SAB activities and products, contacted Board members, interviewed
Agency personnel (current and previous), and solicited input from the public. Our goal was to obtain
a broad view of the SAB, as it is and as it is perceived to be by others.
The Science Advisory Board: What's Next? is the result of that effort. It should be noted,
however, that this work builds upon the first self-study conducted by the SAB in 1989. For your
convenience, Appendix A contains important excerpts from the 1989 Mission and Functioning of
the Science Advisory Board report.
I want to express the thanks of the Board to all who played a part in the production of this report:
the Board members and consultants, its reinvention committee, the staff of the Board, the Agency
staff [particularly the Program Evaluation Division of the Office of Policy, Planning and Evaluation
(OPPE)], and the many members of the public who participated in this review.
I invite all of them—and you, the reader—to join us in the implementation of the more than 40
recommendations which are included in this report. Together, we can make a good SAB even better.
Genevieve Matanoski, M.D., Dr. P.H.
Chair, Science Advisory Board
October 1994
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Contents
1. Executive Summary 1
1.1 SAB Mission 1
1.2 SAB Function 1
1.3 SAB Structure 2
1.4 Selection of SAB Projects 2
1.5 SAB Timeliness 3
1.6 SAB Membership 4
1.7 Inter-Committee and Inter-Advisory Group Interactions 4
1.8 SAB Communications 5
2. Introduction: Why Reinvent Now? 7
3. The Process of the Reinvention Study 9
3.1 Phase I 9
3.2 Phase II 9
4. Findings and Recommendations 11
4.1 SAB Mission 11
4.2 SAB Function 12
4.3 SAB Structure 15
4.4 Selection of SAB Projects 16
4.5 SAB Timeliness 18
4.6 SAB Membership 19
4.7 Inter-Committee and Inter-Advisory Group Interactions 21
4.8 SAB Communications 21
5. Conclusion 24
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Contents (continued)
Appendices
A. Excerpts from the Mission and Functioning of the
EPA Science Advisory Board, October 1989 25
B. Office of Policy, Planning and Evaluation, Program Evaluation Division,
SAB Reinvention—Main Messages from EPA Interviewers 29
C. Solicitation of Answers to Questions about the SAB 31
D. Extra-Agency Interviewees 33
E. Draft Description of ad hoc Subcommittee to Develop Guidelines on
Selection of SAB Projects 34
F. Draft Position Paper on Science/Policy Interface 35
G. Affiliation with the Science Advisory Board 36
H. Glossary of Terms and Acronyms 38
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1. Executive Summary
This report is the SAB's second self-study, following its
Mission and Functioning (MAF) Report of 1989. With a new
SAB chair, a new Administrator, and a continually changing
Board, it is both appropriate and instructive to coasider "rein-
venting the SAB" at this time.
As background for this study, the Board received input from
more than 100 people, including Agency political appointees
(past and present), Agency personnel (from managers to bench
scientists), Board members, representatives of other agencies,
and members of the public.
The main substance of the report is captured in findings and
recommendations related to eight topics:
SAB Mission
SAB Function
SAB Structure
Selection of SAB Projects
SAB Timeliness
SAB Membership
Inter-Committee and Inter-Advisory Group Interactions
SAB Communications
1.1 SAB Mission
1.1.1 Findings
a. There are several different views about what the purpose
of the SAB should be.
b. The legislative language guiding the different SAB com-
mittees is significantly different from one another.
c. While there is general agreement that the SAB should
focus on science issues rather than policy issues, there is
a difference of opinion about what is "science" and what
is "policy."
d. The absence of a succinct mission statement (in addition
to the existing charter) for the SAB has led to confusion
about the mission of the Board—in the public sector, in
the Agency, and inside the Board—and the propriety of
some SAB actions.
c. The self-study is a useful mechanism for reviewing the
first principles of the SAB; (re-)educating SAB members
about the Board; assessing the progress of the Board, as
viewed by the members, the Agency, and the public; and
gaining fresh insights on what further improvements can
be made.
1.1.2 Recommendations
a. The SAB should develop a crisp mission statement.
b.The SAB should communicate its mission statement
broadly.
c. The SAB should routinely review its activities in light of
the mission statement.
d.Thc SAB and the Agency should enter into dialogue to
better appreciate the different views at the science/policy
interface.
c. The SAB should conduct a self-study on a regular (e.g.,
5-year) basis.
1.2 SAB Function
12.1 Findings
a. The SAB provides advice on a range of matters (e.g., the
merit of SAB scientific and technical products, research
needs and management, and emerging environmental
problems) through five major vehicles:
1) De novo Reports —substantial, original works, often
generated at the invitation of top Agency leadership.
2) Review Report—generally, written reviews of
Agency products that are submitted to the Adminis-
trator.
3) Commentaries—generally, written, unsolicited ad-
vice on issues that the SAB feels should be drawn to
the attention of the Administrator.
4) Advisories—recently introduced, written advice to
the Administrator on Agency work products that are
in the midst of development.
5) Consultations—generally, public discussions with
Agency representatives about an issue of concern to
the Agency, at a time when the Agency's approach to
the problem is still being formulated. No consensus
is sought.
b. Increasingly, the Agency would like to come to the Board
early in the process to receive ideas on hnw to address a
technical issue. Similarly, at various points throughout
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the development of a technically based position, the
Agency would like to have the option of receiving ihe
benefit of the SAB's guidance/advice on its selected
approach.
c. Early involvement of the Board may jeopardize the SAB's
utility as an independent, objective peer reviewer at die
end of the process.
d. While Agency access to the SAB can enhance informa-
tion exchange, unlimited and nonpublic interaction be-
tween Agency personnel and the Board members can
jeopardize the Board's perceived—and real—indepen-
dence.
c. The increased use of the "charge" has proven to be an
effective mechanism for focusing the Agency's—and the
Board's—attention on the most important facets of a
particular review.
f. The SAB and staff are working at near-maximum effort.
g.The SAB has limited, but successful, experience in host-
ing workshops on particular issues that should be receiv-
ing greater attention by Ihe Agency.
1.23, Recommendations
a. The SAB should encourage further expansion of the
Consultation concept as a means of leavening the Agency's
thinking at the beginning of its development of scientific
and technical positions.
b.The SAB should cautiously expand the use of its new
work product, the Advisory. However, to retain indepen-
dence, the SAB's subsequent review of the final product,
the panel should have a substantial portion of panelists
who did not participate in the Advisory.
c.Thc SAB should discourage one-on-one involvement
between individual members and Agency personnel on
matters that are before the Board for review. Both SAB
members and Agency personnel should be circumspect
on the matter, involving appropriate SAB staff when
communication .is needed.
d. The SAB should work more closely with the Agency to
fulfill the potential of "the charge" as a mechanism to
sharpen preparations for and expectations of SAB re-
views.
c. The SAB needs to focus its efforts on the most important
issues, improve its efficiency, and "work smarter." How-
ever, the Agency and public need to recognize that the
Board and staff are resource-limited in terms of doing
more.
f. The SAB should conduct public workshops, as appropri-
ate, on topics that are in areas of science and technology
that need greater attention and discussion.
1.3 SAB Structure
1.3.1 Findings
a. The current structure of the SAB is a mixture of
discipline-oriented committees (e.g.. Environmental
Health Committee) and Agency-oriented committees
(Drinking Water Committee).
b. Political appointees have recommended in the past that
the Federal Insecticide, Fungicide and Rodenticidc Act
(FIFRA) Scientific Advisory Panel (SAP) and the Bio-
technology Science Advisory Committee (BSAC) be in-
corporated into the SAB stnicture.
c. The structure of Board evolves over time, responding to
various new issues, new needs, and new requests.
13J2 Recommendations
a. The current mix of discipline-oriented and Agency-ori-
ented committees seems to serve the current needs of the
Board and the Agency, although this matter should be
reviewed on a regular basis.
b. The stnicture of the SAB committees should continue to
evolve to adjust to changing conditions. The leadership of
the Board should periodically consider the need for
changes.
c. Increased cooperation should be sought between BSAC,
SAP, and SAB, short of merging the groups.
1.4 Selection of SAB Projects
1.4.1 Findings
a. The Board's current process for selecting projects is
broadly based through involvement of the Deputy Ad-
ministrator, Assistant Administrators/Regional Adminis-
trators (AAs/RAs), the Council of Science Advisors, the
SAB committees, the Executive Committee, and, on oc-
casion, the Congress.
b.The SAR's current process is not well understood.
c.The SAB selection process will be affected by the
Administrator's newly announced peer review policy.
d. All parties outside of the Agency—and a significant
fraction within the Agency—agree that the SAB should
include some self-initiated activities in its agenda.
e. There is a wide span of reaction to the notion that the
SAB be "involved in policy."
1.4.2 Recommendations
a. The SAB should take steps to inform its various audi-
ences about the project selection process.
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b. The SAB should develop explicit criteria for use by the
committees in guiding their development of self-initiated
projects.
c. The Executive Committee should establish a small project
selection subcommittee to
1) Develop guidelines and criteria to guide the process
for selecting both Agency-initiated and SAB-initiated
projects.
2) Examine adherence to project selection guidelines
and criteria.
3) Seek opportunities for a mixture of members from
different committees to address a given topic.
4) Seek opportunities for greater efficiency.
5) Advise the membership subcommittee (see below)
on the upcoming issues so that appropriate members
might be enlisted.
6) Comment on distribution of activities and resource
levels across committees.
7) Serve as an early warning sentinel concerning emerg-
ing issues.
d.Thc SAB should clarify its understanding of and position
on the science/policy interface.
e.The SAB staff should use elements of OPPE and the
Office of Research and Development (ORD) to help
identify issues that would benefit from SAB involve-
ment.
f. The SAB staff should become more actively involved
with the Agency committees that are implementing the
peer review policy throughout the Agency. Such groups
include
1) The Science Policy Council (SPC)
2) The steering committee of the SPC
3) The Peer Review Advisory Group (PRAG)
4) The office-specific parties who are responsible for
overseeing and evaluating the peer review imple-
mentation
5) The Council of Science Advisors
6) Periodic participation in Office Directors ' staff meet-
ings
g. The chair of each committee should visit with the appro-
priate political appointees at least once a year with the
goal of identifying specific issues for review.
1.5 SAB Timeliness
1.5.1 Findings
a. Timeliness is perceived to be a problem by many within
the Agency, but less so by the Board and many outside
the Agency.
b.The SAB review is only one element in the Agency's
overall development of a position.
c. The SAB has demonstrated an ability to generate reviews
quickly when the clear need arises and the materials are
available.
d.The SAB has achieved its announced goal of reducing the
average length of time between the last public meeting
and transmittal of a report to the Administrator to about
six months.
1.5.2 Recommendations
a. The SAB should take the next step in continuous quality
improvement by adopting a goal of reducing the average
length of time between the last public meeting and trans-
mittal of a report to the Administrator to no more than
four months.
b.To achieve this goal, the following process items should
be explored:
1) Careful selection and review of projects so as to meet
Agency and congressionally mandated schedules.
2) Earlier presentation of background and context to the
SAB committee to avoid the need for extensive,
detailed briefings at the review meeting itself.
3) Specific, succinct charges that focus the review on
the main areas of scientific concern.
4) Careful scheduling of committee meetings to dove-
tail report production with upcoming Executive Com-
mittee meetings. (This should be a matter of discussion
with the Agency during early negotiations on the
charge, in order to have mutual expectations about
delivery of the final report.)
5) Timely delivery of Agency documents to the Board,
sufficient to allow a) critique of the charge in light of
the documents, b) identification of required expertise
and available experts, c) arrangement for adequate
logistics, and d) studied preparation by the panel.
6) Setting priorities and conserving SAB and staff re-
sources.
7) Ensuring that Agency personnel are present at SAB
meetings.
8) Providing portable computers in order to compose
draft text at meetings.
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9) Consistent use of articulate exit debriefings at the
end of the meeting.
10) Greater use of fax and email during report produc-
tion.
11) Using vettors at the committee level and at the
Executive Committee level.
12) Sending documents to lead discussants early enough
that they can work with the Designated Federal
Official (DFO) to resolve concerns prior to the Ex-
ecutive Committee meeting.
13) Greater use of "vetting" for more-or-less routine
reports.
14) Closure on final edits before "vettors" leave Execu-
tive Committee meetings.
15) Experimental use of public conference calls for the
Executive Committee to discuss "routine" reports.
1.6 SAB Membership
1.6.1 Findings
a. SAB panelists can participate on SAB panels in a number
of different categories that are not well understood by
many observers, which is a source of confusion and
inconsistency.
b.The diversity of the Board (in terms of gender and ethnic
origin) has increased significantly in recent years, al-
though further progress is needed in this area, particularly
in the case of minority participation.
c. The SAB has adopted "Guidelines for Service on the
Science Advisory Board" that is increasing the rale of
turnover on the Board. As a result the Board is losing
some of its most involved members who have shaped the
institution and who embody its memory.
d.The current membership selection process involves the
public (ad hoc and by a biannual Federal Register no-
tice), the Agency (by program office and Council of
Science Advisors suggestions), and the SAB (by discus-
sions with the committee chairs).
c. The ultimate selection is appropriately in the hands of the
Administrator.
f. The selection process is not well understood.
g.In some quarters in the Agency there is concern about
possible conflicts of interest related to membership on the
Board.
1.62 Recommendations
a. The membership selection process should carefully con-
sider issues coming before the Board for review.
b.ln addition to subject-matter experts, there should be
members on the Board who have a broad perspective of
and diverse experience with science and the role of
science, in an agency like EPA.
c. The Executive Committee should establish a membership
subcommittee that would
1) Help implement Executive Committee-established
candidate selection criteria.
2) Help identify candidates.
3) Provide general guidance on membership selection.
4) Comment on overall balance, quality, and diversity
of candidates for the Board.
d-The SAB should clearly articulate the member selection
process.
c. The SAB should clarify the roles of "member," "consult-
ant," "liaison," etc.
f. The SAB should augment its current process by con-
certed contact with special sources; e.g., professional
societies.
g.Thc SAB should establish and flexibly apply two 2-year
terms as the "normal tour of duty."
1.7 Inter-Committee and Inter-Advisory
Group Interactions
1.7.1 Findings
a. Increasingly, the SAB has had fruitful interactions with
the FIFRA SAP, through the conduct of a series of joint
reviews and the regular participation of the SAP chair at
Executive Committee meetings. •
b.The SAB staff has initiated contact with advisory groups
from other agencies to involve them (through charge
questions and/or liaison members) in selected SAB re-
views; e.g., lead paint, indirect exposure assessment, and
"dioxin." The initiative has been supported by AA/Office
of Prevention, Pesticide and Toxic Substances (OPPTS).
c.The SAB has been approached by a European Commu-
nity advisory committee that is generating a report simi-
lar to Reducing Risk. The European group has expressed
an interest in meeting with the SAB to discuss their
mutual findings.
1.7.2 Recommendations
a. The SAB should seek out—on a onetime, issue-driven
basis—additional opportunities to explore the benefits
and disadvantages of interaction with other advisory
groups, other agencies, or other countries; e.g., at least
one liaison member from another agency's advisory com-
mittee for each suitable review.
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b. The SAB should continue its trend toward greater use of
liaison participation and joint reviews between commit-
tees; e.g., at least one liaison member from another
committee for each suitable review.
c. In addition to its membership identification by commit-
tees, the SAB should maintain rosters of SAB members
and consultants by expertise; i.e., identified "clusters" of
epidemiologists, hydrologists, analytical chemists,
paleobotanists, etc., to facilitate formation of multimedia,
multi-disciplinary panels to address crosscutting issues.
1.8 SAB Communications
1.8.1 Findings
a. Communication is important to a successful, effective
SAB.
b. Being in the Office of the Administrator improves com-
munications.
c.The communications within the Agency regarding the
SAB vary; e.g., biweekly reports to the political leader-
ship, bimonthly distribution of Happenings at the SAB,
oral reports at the Administrator's staff meetings, annual
report, etc. There is no comprehensive strategic plan for
communication.
d. The communications with the public also vary; e.g., trade
press reports, introductory brochure, Federal Register
notices, bimonthly distribution of Happenings at the SAB,
etc.
e. Each SAB report is distributed to a standardized list of
roughly two dozen individuals and institutions. In addi-
tion, roughly 200 requests for SAB reports arc processed
every month. And yet, the perception pcrsisLs that the
SAB work products are generally unknown.
f. The SAB is beginning to use the Agency "gopher" con-
nection to the Internet to facilitate public access to SAB
information.
g. The SAB members generally believe that they work on
important issues. However, they often do not know much
about the impact that their reports actually have. Simi-
larly, Agency staff who prepare presentations for the
SAB are often unaware of ultimate disposition of Agency
responses to SAB comments.
1.8.2 Recommendations
a. Improved communications should be a major goal for the
SAB during FY95.
b.The biweekly reports to the political leadership should be
edited and transmitted to the SAB membership and SAB
alumni.
c. The Board should reassess its approach to report distribu-
tion.
d. The mailing list of Happenings should be edited and
more carefully targeted.
e.The SAB should exploit the Internet connection to the
public (including the SAB members and consultants) in
order to expand its communication capability.
f. Greater interaction between the SAB (members and staff)
and top management at the Agency should be encour-
aged.
g. Focused procedures for gaining customer feedback fol-
lowing reviews should be implemented.
h.The Board should constantly and consistently reinforce
its mission.
i. New members should be more effectively introduced to
the Board.
j. The Executive Committee should be conscious of
cost-effective ways of involving more members in the
broader workings or' the Board.
In short, the SAB is a vigorous, independent institution that is
continuing to evolve in its mission of seeking to improve the
quality of scientific, engineering, and economic bases of
Agency decision making.
This self-study has been an important exercise for the Board.
Like the 1989 MAF report, die study demonstrates the benefit
of openly seeking constructive criticism from its various
customers inside the Bozird, the Agency, and the public.
The major conclusions have much in common with the earlier
report:
a. The SAB works and makes a difference.
b. The SAB continually responds to changing conditions in
an evolutionary, not revolutionary, way.
c.The SAB's effectiveness is directly tied to its real and
perceived independence from the Agency.
d. The SAB can serve the Agency in a number of different
ways:
1) Advising role; c\, consultations and advisories
2) Rigorous peer review role; cf., reports
3) Self-initiated activities; cf., commentaries
e. There is room for continual improvement, especially in
the area of timeliness, membership, and communications.
This report will be complemented by a study of the SAB staff
office to be conducted by the Management and Organization
(M&O) Division of the Agency's Office of Administration
and Resource Management. It will constitute an updating of
the 1989 M&O study of the SAB staff office.
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Many of the more than 40 recommendations from this study
should be implemented during FY95. Coupled with the rec-
ommendations from the upcoming M&O study, these data
will provide the reinvention fuel to power the SAB to the
brink of the next century.
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2. Introduction: Why Reinvent Now?
The SAB is a vigorous, independent institution. Starting as a
fledgling, congressionally mandated organization in the
mid-1970s, the SAB has become an active force in bringing
sound scientific and engineering information to bear on the
technical aspects of both EPA's structure and its important
regulatory decisions and guidance to the public.
The SAB currently maintains an active roster of 100 members
and 300 consultants. These human resources are divided
among 10 different standing committees,' coordinated through
an Executive Committee. The committees of the Board con-
duct roughly 60 public meetings and generate over 30 written
reports a year. The work of the SAB is supported by a staff
office of 18 full time EPA employees, operating on a budget
of just under $2M.
In 1989, the Board conducted its first self-study.2 Led by Dr.
William Lowrance of Rockefeller University, a small group3
examined many aspects of the Board's operation; from mis-
sion to membership, from structure to resources. The execu-
tive summary of that report, along with its findings and
recommendations are included in this report as Appendix A.
In addition, the SAB staff office was studied by EPA's
Management and Operations Division/' In the intervening five
years both the Board and the staff office have teken action on
most of the recommendations contained in those two reports.5
Specific evolutionary modifications that reflect flexibility,
responsiveness, and innovations made, in part, in response to
the reports include the following:
Provision of an explicit ecological focus through the estab-
lishment of the Ecological Processes and Effects Com-
1 Clean Air Act Compliance Analysis Council (CAACAC)
Clean Air Scientific Advisory Committee (CASAC)
Drinking Water Committee (DWC)
Ecological Processes and Effects Committee (EPEC)
Environmental Economics Advisory Committee (EEAC)
Environmental Engineering Committee (EEC)
Environmental Health Committee (EHC)
Indoor Air Quality'Total Human Exposure Committee (TAQC)
Radiation Advisory Committee (RAC)
Research Strategies Advisory Committee (RSAC)
1 Report of the Mission and Functioning Committee, SAB, ! 989.
The 1989 report provides valuable information and insights that have
benefited the writers—and will benefit the readers—of this document.
' Dr. Paul Deisler (Consultant: Houston, TX), Dr. Roger McClellan (CUT,
President: Research Triangle Park. NC), and Dr. C.H. Ward (Rice
University).
* Keport of the Management and Operations Division. U.S. EPA, 1988.
5 Action on these recommendations arc generally chronicled in the Annual
Reports of the SAB staff.
mittee, plus addition of an at-largc Executive Committee
member with expertise in the area of ecology
Provision of an explicit economics focus through the estab-
lishment of Environmental Economics Advisory Com-
mittee
Establishment of the Clean Air Act Compliance Analysis
Council
Two-year experiment with an ad hoc membership subcom-
mittee
Increase of 25% in the number of committees and 50% in
the number of members
Greater integration among standing committees through the
use of liaison members on specific issues
More joint reviews with the Scientific Advisory Panel
Greater emphasis on the executive nature of the Executive
Committee through planning and interaction with top
management of the Agency
Acceptance of a request to lead a study of environmental
futures
Use of discussants and vcttors to deal with reports from
committees
Introduction of annual SAB membership meetings
Introduction of the consultation as a means of providing
technical input to the Agency early in the process
Introduction of advisories and commentaries as means of
providing technical input in new ways
Adoption of guidelines on terms of service on the SAB
Adoption of explicit procedures for disclosure of potential
conflicts of interest at public meetings
Adoption of an SAB-wide policies on the release of draft
documents and privately produced transcripts of SAB
meetings
Greater emphasis on developing the "charge" for SAB
projects
Experimentation with taking on regional-focused reviews
Use of explicit criteria ;o guide selection of SAB projects
Improvement in the timeliness of delivery of reports
SAB representation on the Science Policy Council, the
Deputy Administrator-chaired group dealing with sci-
ence policy issues
Upgraded publication of Happenings at the SAB
Increased sophistication of the annual report
Greater accessibility to and use of computers
Restructuring of the staff to provide a focus for administra-
tive support
Increased professional growth opportunities for SAB staff
In 1992, Carol Browner came to F.PA as a part of a new
administration and quickly indicated that there was a "bias for
7
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change" at the Agency. Since her arrival she has initiated a
number of new thrusts (e.g., a new strategic plan'' and an
emerging process for defining environmental goals) and clearly
articulated her commitment to a policy of environmental
protection that is based on sound science. This approach
meshed nicely with the government-wide Total Quality Man-
agement (TQM) thrust that urged organizations and people to
continuously seek out methods for improving operations,
products, and services.
In the fall of 1993 Administrator Browner appointed Dr.
Genevieve Matanoski of The Johns Hopkins University as the
new chair of the SAB Executive Committee, replacing Dr.
Raymond Lochr of the University of Texas who had led the
SAB for five years. Dr. Matanoski took the reins of a well
regarded institution with a number of unique accomplish-
ments to its credit.7
The influence of the SAB has been felt beyond EPA. For
example, numerous inquiries have been received from differ-
ent state and local jurisdictions." Also, a number of federal
agencies have visited the SAB with an eye toward improving
their own advisory process. In 1993 Vice President Gore
issued his National Performance Review9 in which he made a
series of recommendations, one of which bears directly on the
concept of the SAB.10 He also issued a scries of challenges
that would "streamline" government as we know it. Adminis-
trator Browner passed on that challenge to all offices in the
Agency so that they would rethink their own operations.
Therefore, in light of all of the changes that have transpired
over the past five years, both internal and external to the SAB,
Dr. Matanoski judged that 1994 would be an appropriate time
to take an in-depth, objective look at the structure and func-
tion of the SAB. Consequently, the Executive Committee
authorized the establishment of an ad hoc reinvention com-
mittee (RC)," chaired by Dr. Matanoski, to conduct a self-
study of the SAB and report back to the SAB membership on
the important findings and recommendations that should guide
the organization into the next century.
Section 3 of this report describes the conduct of the reinven-
tion study itself. Section 4 contains the findings and recom-
mendations in each of eight specific areas. Section 5 is a brief
summary of the major conclusions of this study. The report
contains five appendices that amplify on points made in the
main text. Also, the PED and MAF reports should be con-
sulted for additional background and information.
* "The New Generation of Environmental Protection: A Summary of
EPA's Five-Year Strategic Plan," July 1994. (EPA-200-2-94-001).
' For example. Future Risk (1988) did much to determine the thrust of
EPA research in this decade. Similarly, Reducing Ri.sk (1990) highlighted
the importance of comparative risk in an era of limited resources.
* Wilhin the past three years inquiries about how one might develop an
SAB-likc organization have been received from the governors' offices of
California, Washington, and Florida. In addition, the mayor's office of
the cily of Columbus, OH, has established an Environment Advisory
Committee, modeled closely after the SAD.
* Notional Perfornmncc Review: Reinventing the Federal Government,
Office of the Vice President, 1993.
13 One of the recommendations was that all science-related regulatory
agencies should have a Science Advisor)' Board, implicitly modeled after
the SAB of the EPA.
1' The RC membership was composed of all members of the Executive
Committee who were not currently serving as chairs of standing
committees.
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3. The Process of the Reinvention Study
In keeping with the tenets of TQM. the reinvent ion study was
based on a) an attempt to align with the Board's "customers,"
both inside and outside EPA, b) the considered insights of
SAB committees, and c) extensive data collection. The intent
of the data collection was to gather a range of perceptions
about the SAB and capture individual ideas and innovative
suggestions. The study was not designed to provide a statisti-
cally valid view of the Board and its activities.
3.1 Phase I
During Phase 1 of the study, attention was focused primarily
on the SAB and the Agency. Among the activities in Phase I
were the following:
a. The Program Evaluation Division (PED)12 of OPPE agreed
to conduct a study of the Agency's reaction to the SAB.
Working with SAB Reinvention Committee (RC) staff,13
the PED group interviewed over fifty EPA employees,
from the Administrator's office to the lab bench in Cin-
cinnati and Research Triangle Park. Coupled with focus
group sessions, the PED group succeeded in reaching a
range of Agency customers who could not have been
credibly contacted by SAB staff alone.
The results of the work are contained in "Science Advisory
Board Reinvention Project: Agency Interview Data Sum-
mary," (Publication number EPA-230-R-94-017). A syn-
opsis of the take-home messages is found in Appendix B.
b. Ms. Yvette Hellyer14coordinated an internal SAB staff-led
effort to develop and distribute a questionnaire to readers
of the SAB newsletter, Happenings at the SAB. Four
hundred questionnaires were distributed to those on the
mailing list. Eighty-five responses were received and
results compiled. The copy of the questionnaire and
summary of responses are found in Appendix C.
" Pam Stirling, PED Director, appointed Len Flcckcnstcin to coordinate
the project. The project leader was Kristina Hcinemann, wtio was ably
assisted by Gabriella Lombardi, Joel Jones, Gwen Wise, Lynda
Dowling, and Charlotte White. Their efforts provided unique, critical
insights that could not have been captured otlierwise. As such, their
report was un invaluable source of data for this study.
" The SAB reinvention staff included Don Barnes (Chair), Randall Bond,
Janice Cuevas, Manuel Gomez, Yvcltc Hellyer, and Jason Holstine.
Ms. Hellyer (OPPT) served a 3-month detail to the SAB stiff office,
developing questionnaires, organizing information, interfacing with the
PED operation, etc. The RC is indebted to her for her considerable
management and organizational skills.
c. Members of the RC conducted telephone interviews with
current and former political appointees at the Agency.
See Appendix D.
d.The SAB standing committees were invited to conduct
their own self-studies by reviewing their experience and
work products of the years. The goal was to identify those
aspects of their efforts that were particularly successful—
by various measures—and that might be used to guide
such efforts in the future. The EEC and the RAC" ac-
cepted the invitation and their reports will be released by
the SAB in early FY95.
3.2 Phase II
In Phase II of the study, die focus shifted to perceptions of the
SAB held by those outside the Agency. There were three
principal activities in this portion of the study:
a. The SAB staff conducted telephone interviews with rep-
resentatives of the business community and the environ-
mental community. The organizations and interviewees
were selected by the RC staff from suggestions submitted
by SAB members and members of the staff themselves.
The staff consciously sought individuals who were likely
to have some knowledge of the SAB. See Appendix D.
b.Thc SAB staff conducted a "benchmarking" study by
interviewing individuals closely involved with technical
advisory committees for other groups, both inside and
outside government. See Appendix D.
'I"he RC also conducted two public meetings: June 14, 1994,
and Sept 8, 1994. In addition, the group conferred on a near
monthly basis to discuss progress and to provide guidance for
the RC staff.
On July 14, 1994, the RC met with the Executive Committee
to discuss the results of the reinvention study up to that time.
In a morning session the group met with Agency managers""
to gather additional information. In a public session in the
afternoon, they discussed draft findings and recommenda-
" Even before the reinvention exercise began, Dr. Oddvar Nygaard, former
RAC Chair, had initiated the committee's own "retrospective study." The
RAC, the RC, and the SAB owe Dr. Nygaard a debt for adapting his
study to the current effort.
" Dr. Roger Cortesi, ORD; Dr. Elizabeth Cotsworth, Office of Solid Waste;
Dr. Tudor Davies; and Elizabeth Milewski. OPPTS.
9
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lions. Following a public meeting on September 8, 1994, the
RC prepared a final report for review and acceptance by the
Executive Committee during a conference call in late Septem-
ber. The Executive Committee intends to present the report to
the entire SAB membership at the annua! meeting on October
26. 1994, for their reaction, which will guide implementation
of the recommendations.
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4. Findings and Recommendations
In general, this reinvention study is a natural extension of the
SAB's first self-study, The MAF Report (1989), which sum-
marized important information about the origins of the SAB,
its mission, and its operations. Coupled with the annual re-
ports of the SAB staff" and the draft history of the Board,1"
the MAF Report provides a rich source of insight about the
operations of the SAB and forms an important companion
document to this report. Major highlights and recommenda-
tions from the MAF report are found in Appendix A.
The history of the SAB since the 1989 report har. been one of
a natural evolution, with the main trunk continuing to grow on
its set course, while side branches have sprouted, developed,
and often generated fruit of their own. In fact, to restrict the
size of the current report, the RC reaffirms the findings and
recommendations in the MAF Report, except in those in-
stances in which specific findings and recommendations in
this report specifically alters them.
In this section, the RC presents its findings and recommenda-
tions in each of eight major areas of interest that emerged
during the course of the study.
4.1 SAB Mission
4.1.1 Findings
a. There are several different views about what the purpose
of the SAB should be.
Taken together, the data gathered for the reinvention study
revealed a wide range of what the mission of the Board is or
should be. Some regarded the SAB as a type of "science
Supreme Court" that should render final peer review opin-
ions—when asked—about the scientific and technical basis of
the Agency's positions. Others felt that the SAB should be a
more collegia! advisor, regularly available to provide real
time counsel as the Agency struggles with scientific and
technical matters. Still others—most often, those outside the
Agency—felt that the SAB should be independent, proactive,
and directive in telling the Agency how to address and react to
scientific and technical issues.
" Annual reports ofihe SAB have been produced each year since the
mid-1980s.
Bush. Perry, "Uneasy Partners A History and Analysis of the EPA's
Science Advisory Boanl."This draft was commissioned by the SAB Staff
and accepted by the KC as information in 1990.
b.Thc legislative language guiding the different SAB com-
mittees is significantly different from one another.
Separate pieces of legislation mandate specific committees
within the SAB; other committees are referenced, but not
explicitly named." Therefore, the results are somewhat differ-
ent in each case. For example, the Clean Air Act (1977)
explicitly calls for CASAC to advise on the possible adverse
economic, social, etc., impacts of clean air standards. In
contrast, ERDDAA speaks of the role of the SAB as more
restricted to scientific and technical issues.
c. While there is general agreement that the SAB should
focus on science issues rather than policy issues, there is
a difference of opinion about what is "science" and what
is "policy."
Science and policy are both multifaceted subjects,20 and in the
context of the EPA's work they can interface in many ways,
interpenetrating each other. The SAB has traditionally tried to
avoid areas that clearly involve policy or policy judgments.
On the occasions where this has been necessary, the SAB has
carefully acknowledged this fact and tried to offer its reasons
for doing so; cf., the caveat in Reducing Risk, the SAB's 1990
report on relative environmental risks.21
However, as evidence in interviews and responses to ques-
tionnaires, some Agency managers believe that the Board
moves into policy areas with sufficient regularity to be of
concern.
d. The absence of a succinct mission statement (in addition
to the existing charter) for the SAB has led to confusion
about the mission of th: Board—in the public sector, in
the Agency, and inside the Board—and about the propri-
ety of some SAB actior.s.
" For example, the SAB was established under the Environmental
Research, Development, and Demonstration Authorization Act
(ERDDAA) of 1978. CASAC was established in the Clean Air Act of
1977. CAACAC was established under the Clean Air Act Amendments
of 1990. The activities of son»e o:her committees are referenced in
legislation; e.g., IAQC in the Superfund legislation ami DWC the Safe
Drinking Water Act.
" This issue is discussed more fully in Sections 3.1 ("SAB's Purview
Science for Environmental Protection") and 3.2 "Consideration of
Science in Context") on pp. 6-8 of the MAF report.
" "...This particular project was conducted al the request of the EPA
Administrator and addresses a broader range of issues and concerns than
most SAB reports. Consequently, many of the findings and recommenda-
tions in this report have more of a policy orientation than is usually (lie
case."
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A perceived lack of clarity about "proper SAB activity" can
lead to misunderstanding among members of the public, mis-
directed energies among members of the SAB, and differ-
ences between the Agency and the Board. In fact, some such
differences are no doubt inevitable and constitute a sign of
healthy independence of the SAB from the Agency. At the
same time, a mission statement would help improve effective
communication and mutual understanding, if not totally elimi-
nate controversy.
e. The self-study is a useful mechanism for reviewing the
first principles of the SAB; (re-)educating SAB members
about the Board; assessing the progress of the Board, as
viewed by the members, the Agency, and the public; and
gaining fresh insights on what further improvements can
be made.
In conducting this self-study, the SAB has been forced to
confront some fundamental questions about what it is and
what it does. This "looking into the mirror" is valuable in
many ways. For example, this study generates insights as to
how effective the Board is and how it is viewed by others.
Further, it provides an opportunity to explore how other
advisory committees function.
4.1.2 Recommendations
a. The SAB should develop a crisp mission statement.
The mission statement should be a succinct description of
what tlie SAB docs, and why. It should include the following
points:
1) The SAB is independent from the Agency.
2) The SAB is advisory to the Agency.
3) The SAB seeks to improve the quality of the scien-
tific and technical basis of activities at EPA, both the
production of that basis and its use in Agency deci-
sion making.
4) The types of activities of the SAB are found in the
charters of the SAB, CAACAC, and CASAC. These
may be alluded to but are not necessarily all enumer-
ated in the mission statement.
The MAF report provides a good base upon which to con-
struct a good mission statement" and should be consulted
when developing an updated mission statement.
b.The SAB should communicate its mission statement
broadly.
By repeated, widespread use, a clear and succinct mission
statement can provide, clarify, and publicize an identity for
the organization. Such a widely understood identity can help
the members to better understand their function and the Agency
and the public to better use the products of the SAB.
" Sections Z2 ("SAB's Aiding-and-extending Mission") and 2.3 ("SAB's
Auditing-and certifying Mission"), pp. 4-6, MAF report.
c. The SAB should routinely review its activities in light of
the mission statement.
The SAB staff director should report semiannually to the
Executive Committee on the extent and distribution of the
Board activities, compared to what is envisioned in the mis-
sion statement and the charters of SAB committees. This
review will help to-inculcate the mission statement in the
collective minds of the Board and to make it a reality in their
individual actions.
d.The SAB and the Agency should enter into dialogue to
better appreciate the different views at the science/policy
interface.
The different perceptions about the presence and extent of
SAB involvement in policy issues needs to be addressed
directly. As noted in the findings, to an extent, tlie different
viewpoints arc a healthy sign of independence of the Board
from the Agency. Therefore, no amount of discussion should
be expected to resolve all issues. However, a frank exchange
will help both the SAB and the Agency to better understand
the perspective of the other.
A third party-facilitated meeting between selected SAB mem-
bers and Agency managers, using recent SAB reports as
examples, could clarify the different viewpoints, spotlighting
the many points held in common and highlighting those areas
where differences exist and are likely to remain.
e. The SAB should conduct a self-study on a regular (e.g.,
5-year) basis.
The self-study experience of the Board over the past six years
has shown the value of such a review—to the Board, the
Agency, and the public. Given the new rotational membership
policy, we can anticipate that the SAB chair, the members of
the Executive Committee, and more than half of the Board
will turn over within a five-year period. Therefore, it is
important that the Board periodically reexamine its roots, its
purpose, and its direction in some disciplined way. In addi-
tion, a regular assessment of the Board's progress and promise
will highlight areas where TQM improvements can be made.
4.2 SAB Function
4.2 J Findings
a. The SAB provides advice on a range of matters (e.g., the
merit of SAB scientific and technical products, research
needs and management, and emerging environmental
problems) through five major vehicles:
1) De novo Reports—substantial, original works, often
generated at the invitation of top Agency leadership.
2) Review Reports—generally, written reviews of
Agency products that are submitted to the Adminis-
trator.
12
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3) Commentaries—generally, written, unsolicited ad-
vice on issues that the SAB feels should be drawn to
the attention of the Administrator.
4) Advisories—recently introduced, written advice to
the Administrator on Agency work products that arc
in the midst of development.
5) Consultations—generally, public discussions with
Agency representatives about an issue of concern to
the Agency, at a time when the Agency's approach to
the problem is still being formulated. No consensus
is sought.
In recent years the SAB has generated a few De novo Reports
at the request of the Administrator; cf., Future Risk, Reducing
Risk, and Beyond the Horizon (a work in progress by the
Environmental Futures Committee). These efforts have had
major impacts on the Agency—and beyond—but have raised
concerns in some quarters about the SAB possibly delving
into policy matters that go beyond strictly technical issues.
The Review Reports have been the principal staple of the SAB
for many years. Many of the Review Reports deal with Agency
technical work products that will form the basis of Agency
risk management decisions.
The relatively recent introduction of Commentaries has pro-
vided an outlet for the SAB committees to express themselves
on an as-needed basis. Some of these commentaries have had
major impacts; e.g., EEC commentary on modelling and the
RAC-DWC commentary on radon in drinking water. In most
cases, top management has welcomed Commentaries as valu-
able advice from a unique perspective. In some cases. Agency
personnel have been concerned that Commentaries impinge
on issues in the risk management realm, without an apprecia-
tion of the constraints (legislative and resource) under which
Agency managers must operate.
The most recently introduced SAB vehicle, the Advisory,
came into being as a response to an Agency-expressed need
for real-time collcgial advice (cf., peer involvement), in'addi-
tion to an end-of-process formal peer review. The Advisory
occurs at a point beyond that at which a Consultation and
before that at which a Review Report would be appropriate.
The Consultation is more of a collcgial discussion than it is a
peer review. No report is written. A standard "Notice of
Consultation" informs the Administrator that the SAB has met
with the Agency on a particular topic, but no details are
provided and no response is expected. SAB members arc free
to provide oral and/or written comments as individuals. The
intent is to leaven the Agency's thinking with a range of ideas/
approaches to consider.
This approach has been well received by the Board members
and by the Agency. The public meeting involves compara-
tively little preparation by either the SAB or the Agency.
From the Agency's point of view, the Consultation is a
low-risk and potentially high-payoff encounter.
b. Increasingly, the Agency would like to come to the Board
early in the process to receive ideas about how to address
technical issues. Similarly, at various points throughout
the development of a position, the Agency would like to
have the option of receiving the benefit of the SAB's
guidancc/advicc on its selected approach; hence the Advi-
sory.
In recent months a number of offices have been "pushing the
envelope" of the Consultation. As strictly defined, the Con-
sultation occurs before the Agency has determined how it is
going to approach a prob!!em. Operationally, this means that a
Consultation would occur before the Agency had developed a
document. Lately, program offices have been coming to the
SAB staff with "draft documents that do not yet represent
Agency positions" and fcr which they would like some SAB
reaction.
Therefore, in FY94 the SAB introduced the Advisoty.
c. Early involvement of i:he Board may jeopardize the SAB's
utility as an independent, objective peer reviewer at the
end of the process.
The SAB has been concerned about maintaining its indepen-
dence from the development of an Agency document in order
that the Board might provide the perception and reality of a
rigorous, independent, objiictive peer review of the Agency's
final document. The more the SAB is involved in providing
advice on a work under development (i.e., generating an
Advisory), the more difficult it is to maintain that indepen-
dence—in reality, and in the eye of public.
d. While Agency access to the SAB can enhance informa-
tion exchange, unlimited and nonpublic interaction be-
tween Agency personnel and the Board members can
jeopardize the Board's real and perceived independence.
Experience has shown that close interaction between Agency
personnel and Board members can lead to improved Agency
products. However, this nonpublic, "thesis advisor" role is at
variance with the rigorous peer review function envisioned by
many on the SAB and in the public.
'llierefore, the Board and the Agency need to be circumspect
in their interactions, recognizing that they have a responsibil-
ity to maintain an arms leng th relationship, so as to conduct a
credible peer review at the end of the process, if so requested.
e. The increased use of the "charge" has proven to be an
effective mechanism for focusing the Agency's—and the
Board's—attention on the most important facets of a
particular review.
Over the past five years the SAB has more rigorously fol-
lowed the practice of negotiating a "charge" with the Agency
prior to conducting a review. The charge is a mutually agreed
upon set of questions that will be answered by the Board
during the course of its meeting. The charge is "defining; but
not constraining"; i.e., it clarifies the Agency's need and the
SAB's focus, but it does not restrict the Board from providing
13
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technical comments on any or all portions of the Agency's
document.
Increasingly, the charge is being viewed by the Agency and
the SAB as a valuable tool for opening clear channels of
communication and forging quality reviews.
f. The SAB and staff are working at near-maximum effort.
Most SAB members arc working near maximum capacity.23 If
additional functions were to be adopted by the Board, it could
mean the addition of new members to take on those tasks.
All of the SAB staff is working at near-maximum capacity.
While responsibilities and operations have broadened, the
FTEs available to carry out the work have actually decreased
by more than 20% in the past 5 years. Even though efficien-
cies have been gained tlirough new equipment, training, and
centralized office functions, the office has, on occasion, fallen
short of providing the SAB members with the level of support
they feel they need to provide timely, quality advice to the
Administrator.
The SAB is aware that the Office of Management and Opera-
tions will be studying the organization and operation of the
SAB staff office this fall. However, study alone will not solve
the problem.
g.The SAB has limited, but successful, experience hosting
workshops on particular issues that should be receiving
greater attention by the Agency.
Two years ago the SAB hosted a workshop on technical issues
associated with leaching mechanisms. The proceedings were
videotaped and made available to EPA programs and regions.
As a direct result of the workshop, the Environmental Engi-
neering Committee sent a Commentary to the Administrator
identifying particular issues that needed to be addressed in
any Agency modeling and testing associated with leaching.24
The effort was well received inside and outside the Agency.
Several other crosscutting technical issues exist that could
benefit from an objective workshop sponsored/promoted by
the SAB.
4*2.2 Recommendations
a. The SAB should encourage further expansion of the
Consultation concept as a means of leavening the Agency's
thinking at the beginning of its development of scientific
and technical positions.
There is a real need for early thoughts to help the Agency
obtain a full spectrum of possibilities and to gain a sense of
the breadth of views that exists in the technical community,
11 However, some SAB Committees have encountered unexpected and
disconcerting slack periods due to postponement or cancellation of
reviews by the Agency.
v "Lcaeliability Phenomena—Recommendations and Rationale for
Analysis of Contaminant Release," (EPA-SAB-EEC-92-003)
before Ihe Agency commits itself to a particular direction of
development.
b.The SAB should cautiously expand the use of its new
work product, the Advisory. However, to retain indepen-
dence, the SAB's subsequent review of the final product
should have a substantial presence of panelists who did
not participate in the Advisory.
The aim of the Advisory is to emphasize advice on how the
Agency is addressing an issue, rather than peer review on how
the Agency has dealt with the issue to date. By pointing out
potential problems early on and suggesting alternative ap-
proaches, the SAB can help the Agency explore creative ways
to address the complex technical issues that lie at the heart of
many environmental problems.
In FY94 the Board transmitted two Advisories to the Adminis-
trator.
The Board needs to ensure that review of a final product that
has benefited from an Advisory is independent and objective.
Therefore, the final review group should have a substantial
presence of new panelists. As a practical matter, one could
also assign more senior SAB members (in terms of length of
SAB service) to the Advisory group, with the expectation that
they would have rotated off the Board by the time the final
product comes to the committee for formal review.
c. The SAB should discourage onc-on-onc involvement
between individual members and Agency personnel on
matters that are before the Board for review. Both SAB
members and Agency personnel should be circumspect
on the matter, involving appropriate SAB staff when
communication is needed.
The SAB has an obligation to the Agency and to the public to
remain fair and objective. Therefore, the Board must—in fact
and in appearance—remain independent throughout the re-
view process. This does not preclude the SAB practice of
sharing draft reports with the Agency and the public as it
seeks reaction on matters of fact, clarity of expression, and
completion of the charge. It is the responsibility of the SAB
staff to ensure that interactions between the Board and the
Agency do not jeopardize the public trust in that relationship.
d. The SAB should work more closely with the Agency to
fulfill the potential of "the charge" as a mechanism to
sharpen preparations for and expectations of SAB re-
views.
The charge should continue to evolve as a central focusing
device for SAB reviews. The charge should become a negoti-
ated document between the SAB and the Agency. Input to the
charge can be sought from other parties who have technical
expertise and concerns about the matter at hand. These techni
cal queries could be raised by other agencies, other advisory
groups, and/or members of the public.
e. The SAB needs to focus its efforts on the most important
issues, improve its efficiency, and "work smarter." How-
ever, the Agency and public need to recognize that the
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Board and staff are resource-limited in terms of doing
more.
As the scope of SAB functions expand, the Board will have to
continue to improve its operating procedures. However, even
with these improvements, it is clear that the Board and the
staff will require additional resources to fulfill the expecta-
tions of the various parties. For example, in FY94 the Board
was able to address roughly a third of the requests received
from the program offices and regions. With the implementa-
tion of the new Agency peer review policy," the number of
requests directed to the Board is likely to rise even higher.
f. The SAB should conduct public workshops, as appropri-
ate, on topics that arc in areas of science ard technology
that need greater attention and discussion.
Given the success of previous workshops, it would be useful
to use this mechanism more frequently.
43 SAB Structure
43.1 Findings
a. The current structure of the SAB is a mixture of
discipline-oriented committees (e.g., Environmental
Health Committee) and Agency-oriented committees
(Chinking Water Committee)
The structure of the Board has evolved over time, as a result of
historical precedents, congressional direction, and Adminis-
trator requests. For example, the two most recently added
committees—ERAC and CAACAC—represent, respectively,
a discipline-oriented committee and an Agency-oriented com-
mittee. The current state of the Board is more a result of
pragmatic reaction than strategic design.
b. Political appointees have recommended in the past that
the FIFRA SAP and the BSAC be incorporated into the
SAB structure.
The former AA/OPPTS (Linda Fisher) recommended that the
two technical advisory committees in her office (SAP and
BSAC) become a part of the SAB. She felt that advice on
technical matters to the Agency should come through a single
advisory body. Subsequent to that recommendation, there
have been a number of discussions and internal studies on the
matter. To date, there has been little enthusiasm to implement
the recommendation, given die current resource constraints
and somewhat different operating methods of the groups.
Also, increased participation by the SAP chair in Executive
Committee activities, coupled with increased joint reviews,
has led to closer cooperation between SAB and SAP than has
existed in previous years.
c. The structure of the Board evolves over time, responding
to various new issues, new needs, and new requests.
Since the MAF report, the number of committees have in-
creased by 25%: in one case, in response to a congressional
initiative (CAACAC. under the Clean Air Act Amendments
" Administraior's memorandum, "Peer Review Program," June 7, 1994.
of 1990) and, in another case, in response to a request from the
Administrator (KEAC, as a result of a 1990 request).
4.3.2 Recommendations
a.The current mix of discipline-oriented and
Agency-oriented committees seems to serve the
current needs of the Board and the Agency, although this
matter should be reviewed on a regular basis.
Once a year, the Executive Committee should reexamine its
committee structure to determine how well it matches with
shifting Agency priorities and emerging issues of greatest
importance. The Executive Committee should regularly con-
fer with the Administrator to determine how best to organize
itself to address the needs and priorities of the Agency. As
structural changes become necessary and following full con-
sideration of questions of implementation, the Executive Com-
mittee should take appropriate action and describe any changes
to the rest of the Board at the annual membership meeting in
October.
b. The structure of the SAB committees should continue to
evolve in order to adjust to changing conditions. The
leadership of the Boand should periodically consider the
need for changes.
Each of the committees should regularly address the need for
changes in their structure. For example,
1) With the rising interest in social sciences research,
the EEAC might consider expanding its scope by
changing its aame to the Environmental
Socioeconomics Committee and taking on more so-
cial sciences issues beyond economics. This change
would explicitly acknowledge the presence of non-
economists on the committee and facilitate recruit-
ment of members from a broader range of disciplines
in the future.
2) The EEC might consider changing its name to the
Environmental Engineering and Technology Com-
mittee, thereby acknowledging what is already the
case, while explicitly emphasizing the importance of
technology.
3) The EEC should also explore establishing a special
subcommittee to interact with the Superfund and
Resource Conservation and Recovery Act (RCRA)
programs; i.e., a waste programs subcommittee. This
would provide a clear focus of SAB activity for the
Office of Solid Waste and Emergency Response
(OSWER), one of the largest programs in the Agency,
thereby holding the promise of increasing the inter-
action between the program and the Board.
4) The RSAC should consider enlarging in order to
cover all of the research interests represented on the
Board. This could l>e done by having the chairs of the
standing committees serve as RSAC members or by
having each committee designate a "vice-chair for
R&D" who would serve in this capacity. This
15
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vice-chair would also chair the committee's RSAC-
related review of ORD issue plans.
c. Increased cooperation should be sought between BSAC,
SAP, and SAB, short of merging the groups.
In the absence of greater expressed commitment to the advan-
tages of the merging of the groups, the SAB should remain
separate from the SAP and the BSAC. However, increased
cooperation—including joint reviews of mutually appropriate
issues—should be encouraged. If, at some point in the future,
the Agency determines affirmatively that merging the groups
would be useful and associated resource questions can be
adequately addressed, this recommendation should be revis-
ited.
4.4 Selection of SAB Projects
4.4.1 Findings
a. The Board's current process for selecting projects is
broadly based through involvement of the Deputy Ad-
ministrator, the AAs/RAs, the Council of Science Advi-
sors, the SAB committees, the Executive Committee,
and, on occasion, the Congress.
Each spring the Deputy Administrator directs the AAs/RAs to
send requests for SAB reviews to the SAB staff. This informa-
tion is shared with the Agency's Council of Science Advisors
in order to obtain a cross-Agency perspective. The resulting
lists are provided to the SAB committees to help them con-
struct their activities for the coming fiscal year. On occasion,
the Board is directed by Congress to conduct selected re-
views; e.g., the annual ORD budget review, the recent review
of the multimedia risk assessment for radon, and the review of
the EPA Lab Study.
b.The SAB's cunent process is not well understood.
The above procedure is not generally well understood, par-
ticularly by those who are not a part of the exercise itself; e.g.,
members of the public and Agency scientists who may not
become directly involved in the process. Some of these people
express frustration at not having access to the selection pro-
cess.
c. The SAB selection process will be affected by the
Administrator's newly announced peer review policy.
On June 7, 1994, the Administrator released a peer review
policy that directs that every "major technical work product"
receive independent peer review, preferably by outside ex-
perts. In implementing the policy, regions and program of-
fices are identifying all technical products generated in their
units, the subset of those that are "major," and the mecha-
nisms by which they will obtain peer review. The policy
identifies at least 14 different acceptable peer review mecha-
nisms, of which the SAB is only one.
On one hand, the requests for SAB review may rise dramati-
cally, since the Board is acknowledged as a quality peer
review mechanism thai is viewed as "cost free" to the regions
and the program offices. On the other hand, the SAB staff has
made it clear that the Board should not be viewed as the
preferred mechanism simply "because it is there." In fact, the
staff has indicated that the recognition and availability of
alternative mechanisms should free up the Board to devote its
efforts more exclusively to the broader, cross-Agency issues,
rather than program- or region-specific concerns.
It is not yet clear how these competing views of SAB capabil-
ity and capacity will evolve.
d.All parties outside of the Agency—and a significant
fraction within the Agency—agree that the SAB should
include some self-initiated activities in its agenda.
Historically, a fraction of the Board's activities have been
self-initiated; i.e., reports/commentaries that are not explicitly
requested by the Agency. These activities reflect broader,
independent concerns of the committees, generally born of
their observations about some scientific issue at the Agency;
e.g., the RAC commentary on the different approaches to risk
assessment for chemicals vs. radioactivity.
SAB observers generally believe that such self-initiated activ-
ity is valuable to the process. However, intra- and extra-
Agency parties differ significantly on the percentage of SAB
activities that should be self-initiated.
e. There is a wide span of reaction to the notion that the
SAB be "involved in policy."
This spectrum of views is due to several reasons. First, policy,
like beauty, is oft in the eye of the beholder. Second, as the
National Academy of Sciences noted, while the broad distinc-
tion between risk assessment and risk management is clear,
the boundary between science and policy can be uncertain in
some cases; e.g., determining whether the selection of particu-
lar uncertainty factors is science or policy. Third, the SAB is
often directed to address the policy implications of scientific
findings, but not to tell the Agency what to do in the policy
realm; cf. CASAC charter. Fourth, on occasion the SAB has
been asked to address issues beyond the science/policy inter-
face. In such cases the SAB explicitly acknowledges the fact;
cf., Reducing Risk.
4.4.2 Recommendations
a. The SAB should lake steps to inform its various audi-
ences about the project selection process.
As the Agency's peer review policy takes hold and the SAB's
role therein becomes more clear, it will become increasingly
important that the SAB's project selection process be well
understood. Therefore, the SAB should publicize its project
selection process, inside and outside the Agency, through
organs such as the Risk Newsletter (directed primarily inside
the Agency) and Happenings at the SAB and the SAB staffs
annual report (directed both inside and outside the Agency.)
b.The SAB should develop explicit criteria for use by the
committees in guiding their development of self-initiated
projects.
16
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While self-initiated activities are endorsed by all parties, it
would be wise to provide guidance for the committees and
members as they contemplate proposals for self-initiated ac-
tivities. The RC offers the following as potential criteria:
1) The issue is one that lias conic before the Board in
various guises in the past and based upon specific
comments offered in the past, the Board believes that
more generic guidance would be helpful to the
Agency. For example, the EEC resolution on com-
puter modeling, (EPA-SAB-F.EC-89-012).
2) The issue is one that involves two or more
program offices who do not appear to be coor-
dinating their activities. For example, the RAC
commentary on relative risks of radon,
(EPA-SAB-RAC-COM-93-014).
3) The issue is fundamental to the way science is con-
ducted or interpreted in the Agency. For example,
the RSAC report on the EPA Lab Study,
(EPA-SAB-RSAC-94-015).
4) The issue is one that will help the SAB do a better
job of advising the Administrator. For example, the
RAC retrospective study of its activities (in prepara-
tion).
5) The level of self-initiated activities should not ad-
versely affect (by time and other resource impacts)
the Board's ability to respond to the Agency's prior-
ity needs.
6) The inherent value of a self-initiated activity should
have the potential of being equivalent to that of an
Agency-requested activity.
c. The Executive Committee should establish a small project
selection subcommittee to
1) Develop guidelines and criteria to guide the project
selection process for both Agency-initiated and
self-initiated projects.
2) Examine adherence to project selection guidelines
and criteria.
3) Seek opportunities for a mixture of members from
different committees to address a given topic.
4) Seek opportunities for greater efficiency.
5) Advise the membership subcommittee (see below)
on the upcoming issues so that appropriate members
might be enlisted.
6) Comment on distribution of activity and resource
levels across committees.
7) Serve as an early warning sentinel concerning emerg-
ing issues.
The SAB needs to address its project selection process more
strategically. A project selection subcommittee of the Execu-
tive Committee, working with the SAB staff, can provide
guidance and oversight to help bring this about.
A draft description of such a subcommittee is found in the
Appendix E.
d.Tlie SAB should clarify its understanding of and position
on the science/policy interface.
As noted above, the issue of the science/policy interface has
arisen in a number of quarters. The Executive Committee
should take the lead in drafting a position statement on the
issue that will clarify the Board's view on the matter and will
guide the committees as they conduct their business in the
future. Such a statement should build on material in the MAF
report, particularly Section 3.1 and 3.2 on pp. 6-8. A strawman
draft of such a position paper is found in the Appendix F and
can serve as a starting point for a formal statement.
The Board should be clear in noting where in its reports it is
nudging the science/policy interface and when it is crossing
more directly into the policy arena; cf., disclaimer in Reduc-
ing Risk.
As noted in 4.1.2.d, the RC is recommending that the Board
work with the Agency to conduct a third party-facilitated
forum in which the perceptions of science/policy interface can
be shared and historical cases discussed as concrete examples
of concerns having been raised at the interface.
e. The SAB staff should use elements of OPPE and ORD to
help identify issues that would benefit from SAB in-
volvement.
The range of issues that could/should come to the SAB for
consideration is quite large. For example, more than 300
issues have been identified in the regulatory development
process this summer. The SAB should leverage its limited
resources by working closely with those elements of ORD and
OPPE whose responsibility it is to assure that "good science"
is consistently reflected in Agency positions. This mechanism
should help to identify those issues that could most benefit
from SAB review and input.
f. The. SAB staff should become more actively in-
volved with the Agency committees that are imple-
menting the peer review policy throughout the
Agency. Such groups include
1) The SPC
2) The steering committee of the SPC
3) The PRAG
4) The office-specific parties who are responsible for
overseeing and evaluating the peer review imple-
mentation
5) The Council of Science Advisors
17
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6) Periodic participation in Office Directors' staff meet-
ings
The SAB staff need to become actively involved with those
organizations in the Agency that are most likely to be focus-
ing on science issues of fundamental importance to the Agency.
The SAB staff director is a member of the SPC and its steering
committee, as well as the Council of Science Advisors. In
addition, the SAB staff could benefit professionally, while
augmenting the outreach of the Board, by pursuing some of
the other listed options.
g.The chair of each committee should visit with the appro-
priate political appointees at the Agency at least once a
year with the goal of identifying specific issues for re-
view.
Experience has shown that meetings between SAB committee
chairs and political appointees are especially useful in clarify-
ing ways in which the SAB can be of assistance to the
leadership of the Agency. These encounters provide opportu-
nities for frank exchanges and exploratory discussions that are
very beneficial in identifying specific issues for SAB involve-
ment.
4.5 SAB Timeliness
4.5.1 Findings
a. Timeliness is perceived to be a problem by many within
the Agency, but less so by the Board and many outside
the Agency.
The questionnaires from and interviews with people inside the
Agency generally revealed that many of them believe that
"the SAB process is too long." These people refer to the need
for speedy responses in order to meet externally dictated
deadlines.
Board members and respondents from outside the Agency
often cited benefits from reports that are more accurately
described as being "carefully considered" than being "timely."
b.The SAB review is only one element in the Agency's
overall development of a position.
Often a formal SAB review comes at the end of a long
development process that has extended over a period of years.
If the Board recommends significant changes, the
time-requirement consequences of the review can be consid-
erable, even if the review itself is relatively rapid.
c. The SAB has demonstrated an ability to generate reviews
quickly when the clear need arises and the materials arc
available.
The Board has regularly responded to tight deadlines of
congressionally mandated reviews of Agency activities (e.g.,
ORD budget review, multimedia radon risk assessment, and
EPA lab study) in a matter of a few weeks, and sometimes a
few days.
Often the rate-determining step for the Board is the Agency's
developing a focused charge and making materials available
for review, so that a) a meeting date can be firmly established,
b) members can be recruited for the particular review, and c)
members can have sufficient time to study the materials prior
to the meeting.
d. The SAB has achieved its announced goal of reducing the
average length of time between the last public meeting
and transmittal of a report to the Administrator to about
six months.
Just a few years ago the average length of time between the
last public meeting and transmittal of a report to the Adminis-
trator was eight months. Today that time is six months.
The SAB uses a number of devices to get the advice to the
Agency quickly and reliably, including
1) Conducting meetings in public.
2) Summarizing, to the degree possible, responses to
the charge in public session.
3) Increasing the use of computer and electronic link-
ages to facilitate generation, completion, and distri-
bution of reports.
4.5.2 Recommendations
a. The SAB should take the next step in continuous quality
improvement by adopting a goal of reducing the average
length of time between the last public meeting and trans-
mittal of a report to the Administrator to no more than
four months.
The process for report generation should be analyzed to
determine where additional time savings can be gained. In the
spirit of continuous improvement, the Board should challenge
itself to find ways to accelerate the process further, without
sacrificing quality. In fact, greater timeliness can lead to
greater quality in that the advice can often have a greater
impact when it is delivered in a timely manner.
b.To achieve this goal, the following process items should
be explored:
1) Careful selection and review of projects so as to meet
Agency and congressionally mandated schedules.
2) Earlier presentation of background and context to the
SAB committee, in order to avoid the need for exten-
sive, detailed briefings at the review meeting itself.
3) Specific, succinct charges that focus the review on
the main areas of scientific concern.
4) Careful scheduling of committee meetings to dove-
tail report production with upcoming Executive Com-
mittee meetings. (This should be a matter of discussion
with the Agency during early negotiations on the
18
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charge, in order to have mutual expectations about
delivery of the final report.)
5) Timely delivery of Agency documents to the Board,
sufficient to allow a) critique of the charge in light of
the documents, b) identification of required expertise
and available experts, c) arrangement of adequate
logistics, and d) studied preparation by the panel.
6) Setting priorities and conserving SAB and staff re-
sources.
7) Ensuring that Agency personnel arc present at SAB
meetings.
8) Providing portable computers to compose draft text
at meetings.
9) Consistent use of articulate exit debriefings at the
end of the meeting.
10) Greater use of fax and email during report produc-
tion.
11) Using vettors at the committee level, as well as at the
Executive Committee level.
12) Sending documents to lead discussants early enough
that they can work with the DFO to resolve concerns
prior to the Executive Committee meeting.
13) Greater use of 'Vetting" for more-or-less routine
reports.
14) Closure on final edits before "vettors" leave Execu-
tive Committee meetings.
15) Experimental use of public conference calls for the
Executive Committee to discuss "routine" reports.
While some of these techniques have already been used in
selected instances, they have not been routinely a part of all
SAB committee activities. The Board should continue to work
with the Agency to explore additional approaches, insights,
etc. that can be adapted to accelerate the report production/
delivery process.
4.6 SAB Membership
4.6.1 Findings
a. SAB panelists can participate in SAB panels in a number
of different categories that are not well understood by
many observers, which is a source of confusion and
inconsistency.
Participants in SAB panels can carry a numt>er of different
labels; e.g., member, consultant, special government em-
ployee (SGE), SGE without compensation, representative,
liaison, and federal liaison. See Appendix G. The subtle
distinctions among these categories (which are not mutually
exclusive) are not clearly and consistently made between
different committees and different panels.
b. The diversity of the Board (in terms of gender and ethnic
origin) has increased significantly in recent years, al-
though further progress is needed in this area, particularly
in the case of minority participation.
The percentage of women on the Board has increased from
11% in FY92 to 20% in FY94. In the same time span, the
percentage of minorities has increased from 1% to 11%. The
current percentages meet or exceed the percentage of women
and minorities in the population of doctoral scientists and
engineers employed in the U.S.
The Executive Committee has expressed a desire to broaden
the diversity of the Board further, consistent with the prime
objective of enlisting qualified members who can provide the
type of sound, technically relevant advice that is the hallmark
of the SAB.
c.Thc SAB has adopted "Guidelines for Service on the
Science Advisory Board"2" that is increasing the rate of
turnover on the Board. As a result, the Board is losing
some its most involved members who have shaped the
institution and who embody its memory.
In recent years the Executive Committee has adopted mem-
bership guidelines designed to increase the turnover of mem-
bers on the Board.27 As a result, the average length of service
among Board members has decreased by more than 25% in
the space of three years.2* The result is that most of the
members who were present with the Board during its early
years and its most trying years have—or are about to—rotate
off the Board. This transition represents both a substantial
influx of new faces and new thoughts and a potentially
significant loss in understanding of the Board's mission and
its role in the context of liPA.
d.The current membership selection process involves the
public (ad hoc and by a biannual Federal Register no-
tice), the Agency (by program office and Council of
Science Advisors suggestions), and the SAB (by discus-
sions with the committee chairs).
The current membership selection process involves outreach
to many different groups inside and outside the Board, and
inside and outside the Agency.
e. The ultimate selection is appropriately in the hands of the
Administrator.
The SAB charters clearly identify the Administrator as the
appointing official for SAB members. The SAB and the SAB
staff view their membership recommendations as strictly ad-
24 Annual Report of the Science Advisory Board Staff, Appendix D, 1993.
21 Members arc appointed by ihc Administrator for a 2-year term, renewable
twice (6 years). Members who are appointed as chairs of committees
normally serve up to two 2-year terms in that capacity, i.e., 4 additional
years beyond that served as a member.
" The average lenglh of service of SAB members in FY95 will be less than
3 years.
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visory, focusing on technical excellence and balance of legiti-
mate technical points of view.
f. The selection process is not well understood.
Interviews and questionnaires revealed that the membership
selection process is not well understood by many in the
public, the Agency, and the SAB.
g.In some quarters within the Agency there is concern
about possible conflicts of interest related to membership
on the Board.
Over the past two years, there has been increased concern
about conflict-of-intcrest issues in the federal government,
including EPA. Some concerns have been expressed regard-
ing SAB members related to grants and contracts from the
Agency. The SAB staff has worked with the Office of the
General Counsel to gain assurance that the SAB members are
currently adhering to all of the conflict-of-intcrcst require-
ments.
4.6.2 Recommendations
a. The membership selection process should carefully con-
sider issues coming before the Board for review.
SAB members should be selected primarily on the basis of
their scientific, engineering, and economic talent to contribute
credible advice on technical issues that are coming to the
Administrator for decision. This directive places a premium
on accurately anticipating the issues that are likely to come
forward for decisions.
However, while accurate anticipation may be possible for
major issues (e.g., "dioxin" risk assessment), many issues
cannot be projected more than one year in advance.
b.In addition to subject-matter experts, there should be
members on the Board who have a broad perspective of
and diverse experience with science and'the role of
science in an agency like EPA.
Some of the most valuable members of the Board have been
those who have a broad perspective of how science can assist
the decision making process in a regulatory context. Such
members couple technical strengths and insights with practi-
cal wisdom and outlook. These individuals are often helpful in
conducting a rigorous peer review while, if needed, giving
advice on alternative approaches to analyzing limited data
under constraints faced by the Agency.
c. The Executive Committee should establish a membership
subcommittee that would
1) Help implement Executive Committee-established
selection criteria for members.
2) Help identify candidates.
3) Provide general guidance on membership selection.
4) Comment on overall balance, quality, and diversity
of candidates for the Board.
The Executive Committee established an ad hoc membership
subcommittee in 1990 for a two-year trial. Due to a number of
circumstances, including rotation of the subcommittee chair
from the Board, the group was disbanded.
Further experience has revealed the utility of such a group;
and therefore, it should be reinstituted.
d.'llie SAB should clearly articulate the member selection
process.
The SAB should draft and publicize a succinct statement of its
membership selection process. The elements of such a docu-
ment exist in the Guidelines for Service on the SAB, in the
biannual Federal Register notice on SAB membership, and in
materials prepared by the SAB staff in response to focused
FOIA requests; e.g., those dealing with the SAB's review of
the environmental tobacco smoke risk assessment.
e. llie SAB should clarify the roles of "member," "consult-
ant," "liaison," etc.
The membership subcommittee should articulate such distinc-
tions. For example, in general," the roles of SAB members
and consultants are similar, yet distinct. Members are regular
participants appointed by the Administrator. Should a vote on
an issue ever arise, all members can participate, even mem-
bers from committees other than the committee that is leading
the review. By contrast, consultants are ad hoc participants
appointed by the SAB staff director who participate in con-
sensus discussions but do not formally vote on issues before
the committee. Once a consensus is reached, the chair may
explicitly ask if any SAB member objects to the consensus.
Minority opinions can be included from either members or
consultants.
f. The SAB should augment its current process by con-
certed contact with special sources; e.g., professional
societies.
Currently the SAB's contact with outside groups regarding
membership selection is unfocused. The membership sub-
committee should work with the SAB staff to uniformly
contact professional societies and other groups with targeted
messages regarding SAB membership.
g. The SAB should establish and flexibly apply two 2-year
terms as the "normal tour of duty."
The current membership guidelines refer to 2-year appoint-
ments, renewable twice; i.e., 6 years of service. In fact, most
members serve for six years. In order to encourage greater
turnover on the Board, the normal tour of duty should be 4
years, not 6 years. In practice, this directive should be imple-
mented with flexibility so that certain individuals will be
™ CASAC and CAACAC, being separately chartered groups, may be
somewhat different.
20
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asked to serve for a third 2-year term. However, this should
become more the exception than the rule.
4.7 Inter-Committee and Inter-Advisory
Group Interactions
4.7.1 Findings
a. Increasingly, the SAB has had fruitful interactions with
the FIFRA SAP, through the conduct of a series of joint
reviews and the regular participation of the SAP chair at
Executive Committee meetings.
Over the past three years the SAP and SAB have worked more
closely—and productively—together. This development was
prompted, in part, by a recommendation by the AA70PPTS
that the SAP become a part of the SAB. While the staff in the
Office of Pesticide Programs examined the proposal in greater
detail, the two advisory groups moved toward alignment
through joint reviews and through the active participation of
the SAP chair at the meetings of the SAB Executive Commit-
tee.
b.The SAB staff has initiated contact with advisory groups
from other agencies to involve them (through charge
questions and/or liaison members) in selected SAB re-
views; e.g., lead paint, indirect exposure assessment, and
"dioxin." 1"he initiative has been supported by AA/OPFl'S.
A case in point is a review of aspects of hazards posed by lead,
proposed by OPPTS. The Board of Scientific Counselors of
the Agency for Toxic Substance and Disease Registry
(ATSDR) was contacted and arrangements made for liaison
participation by a member of that group on the SAB commit-
tee conducting the review. Further discussions with ATSDR
and the Food and Drug Administration have prompted expres-
sions of interest in joint reviews in the future.
c. The SAB has been approached by a European Commu-
nity advisory committee that is generating a report simi-
lar to Reducing Risk. The European group has expressed
an interest in meeting with the SAB to discuss their
mutual findings.
While travel restrictions and time constraints may limit the
Board's participation in this particular activity, the inquiry
suggests additional avenues and future opportunities to har-
ness extra-government expertise in the process of providing
technical advice to governmental bodies.
4.7.2 Recommendations
a. The SAB should seek out—on a onetime, issue-driven
basis—additional opportunities to explore the benefits
and disadvantages of interaction with other advisory
groups, other agencies, or other countries; e.g., at least
one liaison member from another agency's itdvisory com-
mittee for each suitable review.
The principal role of the SAB is to provide independent,
technical advice to the Administrator of EPA. At the same
time, the Board should carefully explore interaction with
other advisory groups as a mechanism by which the Board can
provide better advice to the Administrator and, collaterally,
have an impact on other groups as well. These outreaches
should be onetime activities with groups external to EPA,
with a thorough evaluation and discussion of the experience
before pursuing additional interactions.
b.Thc SAB should continue its trend toward greater use of
liaison participation and joint reviews between commit-
tees; e.g., at least one liaison member from another
committee for each suitable review.
In the past three years, the Board has moved toward more
interaction among the SAB committees. These have ranged
from individual liaison members for specific reviews, to a
complex, multi-committee coordinated review (RCRA-Regula-
tory Input Analysis), to |)ermancnt mixed-discipline member-
ship on a given committee (CAACAC). These initiatives have
been effective in broadening the scope and applicability of the
advice rendered by the Board. Further explorations in this area
should be pursued.
c. In addition to its membership identification by commit-
tees, the SAB should maintain rosters of SAB members
and consultants by expertise; i.e., identified "clusters" of
epidemiologists, hydrologists, etc. (including generalists)
to facilitate formation of multimedia, multi-disciplinary
panels to address crosscutting issues.
To facilitate sharing of expertise among committees and
among advisory groups, it would be helpful for the SAB staff
to develop rosters of SAB members by "expertise clusters."
4.8 SAB Communications
4.8.1 Findings
a. Communication is important to a successful, effective
SAB.
The SAB is charged with providing advice to the Administra-
tor. In addition, the Board has a responsibility to communicate
with a number of constituencies, including Agency personnel,
Congress, the public, and the Board members themselves. TTie
views of the SAB are acknowledged as authoritative and are
sought after and used in a variety of circumstances. When
such communications are muted or nonexistent, problems
can—and do—emerge. Therefore, good SAB communica-
tions accrues to the benefit of all.
b. Being in the Office of the Administrator improves com-
munications.
By reporting to the Administrator, the Board's advice is heard
directly at the highest level without a lower level filter.
Similarly, interactions with the program offices carry an im-
portant authority that would be missing if the Board were
housed at a lower level. The Board is seen as operating above
the interoffice conflicts.
21
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In like fashion, the Board's association with the Administrator's
office attaches additional weight to its activities, as seen by
other agencies, the Congress, and the public.
c.The communications within the Agency regarding the
SAB vary; e.g., biweekly reports to the political leader-
ship, bimonthly distribution of Happenings at the SAB,
oral reports at the Administrator's staff meetings, annual
report, etc. There is no comprehensive strategic plan for
communication.
While there are many avenues of communication with and
from the SAB, the organization lacks a comprehensive ap-
proach for getting its messages—process issues and reports—
out to the variety of audiences that exist within the Agency;
e.g., political appointees, career staff, scientists.
d.The communications with the public also vary; e.g., trade
press reports, introductory brochure, Federal Register
notices, and bimonthly distribution of Happenings at the
SAB.
Again, while there are many useful activities and products,
there is no coordinated, strategic approach to getting the
Board's messages out to targeted audiences.
c. Each SAB report is distributed to a standardized list of
roughly two dozen individuals and institutions. In addi-
tion, roughly 200 requests for SAB reports are processed
every month. And yet, the perception persists that the
SAB work products are generally unknown.
The requests for SAB reports continue apace. In rare instances
(e.g., Reducing Risk) the requests reach into the tens of
thousands. At the same time, many people comment that the
SAB reports are not readily accessible to individuals outside
the Agency who would like to have them.
f. The SAB is beginning to use the Agency "gopher" con-
nection to the Internet to facilitate public access to SAB
information.
In keeping with the Vice President's initiative, the Agency is
conducting a concerted effort to make its products more
available to the public, both in the U.S. and abroad. There is
now an EPA "gopher" that guides an Internet user through the
labyrinth of Agency resources. In an attempt to make the SAB
work products available to a worldwide audience, the staff
office is mounting SAB reports on the Agency's gopher so
that the information becomes readily available via the Internet.
Although there is a selected audience on the Internet, that
audience is rapidly growing.
g.The SAB members generally believe that they work on
important issues. However, they often do not know much
about the impact that their reports actually have. Simi-
larly, Agency staff who prepare presentations for the
SAB arc often unaware of ultimate disposition of Agency
responses to SAB comments.
In many instances individual SAB members do not receive
informative feedback on the impact of SAB reports. Although
the Administrator may generate responses that arc sent to
members involved in the generation of the report, these re-
sponses arc generally short and do not always reflect how the
Agency will act upon SAB advice in the last analysis.
The PED interviews also revealed that EPA scientific and
technical staff who have made presentations before the Board
are similarly uninformed about the Agency's ultimate disposi-
tion of SAB comments.
4.8.2 Recommendations
a. Improved communications should be a major goal for the
SAB during FY95.
The Executive Committee should establish a small subcom-
mittee to help the staff office develop a strategic plan for
communication within the Board, between the Board and the
Agency, and between the Board and the public, including
Congress. Such a plan should include "customer surveys" of
existing communication efforts. l:or example, the readership
of Happenings should be queried regarding general effective-
ness and customer preferences on format and content. Alter-
native ways of presenting Happenings and reports should be
explored; e.g., different formatting for greater "flash."
b. The biweekly reports to the political leadership should be
edited and transmitted to the SAB membership and SAB
alumni.
The staff office should use the biweekly reports to the Admin-
istrator as a mechanism for instituting a regular communica-
tion to all Board members. The information (<2 pages) should
include concise summaries of recent activities, controversial
items, emerging issues (especially self-initiated activities),
and a near-term calendar. It should not be duplicative of
Happenings.
c. The Board should reassess its approach to report distribu-
tion.
The principal products of the Board are its reports, which
should be of high quality and easily accessible. Therefore, the
Board should examine the best strategic and most effective
distribution procedures. Possibilities include
1) Systematic distribution to the Library of Congress.
2) Assignment of ISBN numbers to reports.
3) Effective use of National Technical Information Ser-
vice.
4) Announcements of reports in professional newslet-
ters.
5) On some occasions, generation of press releases.
6) Greater use of electronic distribution.
d.The mailing list of Happenings should be edited and
more carefully targeted.
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Happenings and other SAB communication organs should be
more carefully targeted at audiences that are most interested
in the information, most affected by the information, and most
likely to use the information, including sharing it with others.
For example, including trade press (e.g., Inside EPA) and
professional society newsletters (e.g., Society of Environmen-
tal Journalists) on the distribution list can have a multiplier
effect Among groups for targeting are the following:
1) EPA lab directors
2) Science staffs and policy staffs at other agencies
3) State environmental directors
4) Directors of research institutions
5) SAB alumni
e. The SAB should exploit the Internet connection to the
public (including the SAB members and consultants) in
order to expand its communication capability.
The SAB should explore the current and emerging mecha-
nisms for making information more readily accessible to a
worldwide audience. Possibilities include using the EPA go-
pher, employing email distribution lists, and establishing an
SAB listserver as a means of quickly getting SAB information
to people who want it. Such mechanisms should be exploited
to sending information out (e.g., introduction to the SAB and
SAB reports) and receiving feedback from the various parties.
f. Greater interaction between the SAB (members and staff)
and top management at the Agency should be encour-
aged.
The SAB committee chairs should meet with Office Directors
prior to formal reviews to clarify any subtleties in the charge
and to discuss mutual expectations. They should try to debrief
personally the relevant office directors following a substan-
tive review. Also, they should make it a point to meet
one-on-one with the AAs at least once a year. Further, person-
nel from the SAB staff should become periodic, if not fre-
quent, participants in the staff meetings of AAs and Office
Directors.
g. Focused procedures for gaining customer feedback fol-
lowing reviews should be implemented.
The SAB should develop a systematic method for assessing
reaction from Agency staff in the wake of an SAB review.
This would include the quality and quantity of advice, its
relevance and timeliness, and views about the SAB review
process itself.
h.Thc Board should constantly and consistently reinforce
its mission.
The mission of the SAB should be continually presented in
simple, plain English. For example, Happenings should have
a brief statement/slogan about the Board's mission as a part of
the masthead.
i. New members should be more effectively introduced to
the Board.
New members receive only a modest introduction to the
Board. Materials should be prepared especially for them30 that
will lead them into the broader workings of the Board. For
example, an introductory session for new members could be
held on the morning of the annual membership meeting.
j. The Executive Committee should be conscious of
cost-effective ways of involving more members in the
broader workings or the Board.
For example, subcommittee authors of reports should always
be present by telephone during Executive Committee discus-
sions of their reports. In some instances it might even be
worthwhile to bring the member(s) to a meeting in which their
report will be discussed.
Another useful mechanism would be for the Staff Director to
attend each meeting of the SAB committees and to summarize
developments in the "greater SAB."
23
,wl This could include, for exanple, the SAB charter, standing committee
charters, the MAF report, (lie RC report, conflict-of-interest information,
and information on administrative rales (e.g.. travel, airlines, etc.).
-------
5. Conclusion
This self-study has been an important exercise for the Board.
Like the 1989 MAF report, the study demonstrates the benefit
of openly seeking constructive criticism from its various
customers inside the Board, the Agency, and the public.
The major conclusions have much in common with the earlier
report:
a. The SAB works and makes a difference.
b.The SAB continually responds to changing conditions in
an evolutionary, not revolutionary, way.
c.The SAB's effectiveness is directly tied to its real and
perceived independence ftom the Agency.
d.The SAB can serve the Agency in a number of different
ways:
1) Advising role; cf., consultations and advisories
2) Rigorous peer review role: cf., reports
3) Self-initiated activities; cf., commentaries
e. There is room for continual improvement, especially in
the area of timeliness, membership, and communications.
This report will be complemented by a study of the SAB staff
office to be conducted by the M&O Division of the Agency's
Office of Administration and Resource Management. It will
constitute an updating of the 1989 M&O study of the SAB
staff office.
The more than 40 recommendations from this study should be
implemented during FY95. Coupled with the recommenda-
tions from die upcoming M&O study, these data will provide
the reinvention fuel to power the SAB to the brink of the next
century.
24
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Appendix A—Excerpts from the Mission and Functioning of the
EPA Science Advisory Board, October 1989
Executive Summary
Over recent years the need and demand for advisory service
by the 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
to take stock, 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 pre-
sents findings and proposals that can be reacted to and imple-
mented 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 by the
whole range of means available to the EPA.
Currently the SAB performs the following functions: review-
ing the quality and relevance of particular regulatory science;
reviewing generic regulatory-scientific approaches; review-
ing research programs; reviewing the technical bases of vari-
ous applied programs; advising on infrastructure] and technical
management issues; advising on emergencies and other
short-notice problems; and advising on broad, strategic mat-
ters.
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; rec-
ommends some alterations in SAB committee structure; and
recommends heightened leadership by the SAB Executive
Committee in relating with the Agency and other organiza-
tions, 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; recom-
mends more deliberate selection, planning, and timing advi-
sory 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 resou rces, the report recommends that the
SAB staff support computers; computer efficiency be im-
proved; and the budget be increased to match the expecta-
tions, 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.
Recommendations and Findings
Recommendation on Terms of Service
The variance in lengths of appointments strikes this subcom-
mittee 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 waiv-
ing the brcak-in-servicc requirement).
Recommendation or?. Executive Committee
Nomination of SAB Candidates
The Executive Committee should systematically solicit sug-
gestions from the committees, survey the capabilities needed
for handling upcoming issues, discuss particular talents, con-
sider 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.)
Recommendations on SAB Recruitment
The Executive Committee should establish an ad hoc member-
ship nomination subcommittee to work with the standing SAB
committees to identify and nominate a diverse roster of the
25
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experts required for the Board, making special effort to recruit
well qualified women and minority scientists. Also this nomi-
nation subcommittee should attend to the balance of represen-
tation from different institutional and technical points-of-view.
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 precau-
tions—if fully observed—seem entirely adequate.
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 ad-
equate. The committee structure matches the Agency's com-
plex organization fairly well. And, especially by employing
ad hoc subcommittees, the SAB is able to put together appro-
priate panels on issues coming up for attention.
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 stand-
ing 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.
Recommendation on Reorganizing to Handle
Ecological Issues Better
The Board should
• establish an Ecological Processes and Effects Committee
(EPEC) with a very broad mandate, having special inter-
est in the effects of contaminants on ecological systems;
• convert the present Environmental Effects, Transport,
and Fate Committee into an Environmental Transport and
Fate Subcommittee of the new EPEC; and
• 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).
Recommendations on Intercommittee
Coordination
• 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.
• Where committees find themselves routinely intersect-
ing, they should consider designating liaisons, perhaps
even appointing a few members to two committees con-
currently. If they find themselves overlapping redun-
dantly, they should review the organizational structure
and territorial boundaries.
• The Board should consider holding an SAB annual meet-
ing at which all of the committees would first conduct
their business separately, then meet in various combina-
tions 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 op-
portunities for coordination, planning, and collegia! ex-
change. Also, it could provide a very effective forum for
discussions with top EPA officials and with leaders of a
variety of external organizations.
Recommendation on Executive Committee
Responsibilities
The Executive Committee should consider its principal tasks
to be
• "Scanning the environmental horizon," sorting out priori-
ties, and setting the broad SAB agenda;
• Representing the Board to the Administrator, the Assis-
tant Administrators, and the laboratory directors;
« Conveying high-level Agency concerns to the SAB;
• Searching out and nominating candidates for SAB ser-
vice;
• 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 Admin-
istrator (CASAC excepted); and
• Representing the Board to the larger scientific and techni-
cal communities and incorporating their input.
Recommendations on Executive Committee
Shaping and Assigning of Committee Tasks
• On all major projects, whether initiated by the commit-
tees or by the Executive Committee or by other sources,
the Executive Committee should, to whatever extent is
appropriate, debate the involvement of committees, the
scope of the issues to be investigated, the general ap-
proaches to be taken, the Agency context surrounding the
projects, and how the projects fit into the environmental
"big picture."
• The Executive Committee must work harder at assem-
bling and tasking the trans-committee teams that increas-
ingly are being required. In consultation with the
26
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committees, it must assign the lead responsibilities, de-
velop clear charges and terms-of-reference for projects,
and carefully allocate personnel and other sources.
• Overall, the Executive Committee must establish and
drive the SAB's "agenda" meant in both its grand and
task-and-timing senses.
Recommendations on Executive Committee
Transmittal of Reports
• The Executive Committee should continue to reserve for
itself the role of transmitting reports to the A dministrator,
with the chair of the Executive Committee (who is the
chair of the SAB) signing the letters of transmittal.
• At the beginning of an SAB inquiry, the Executive Com:
mittee should concern itself principally with the compe-
tence and appropriateness of the committee: assigned to
conduct the study and with the charge to the committee.
• When an inquiry has been completed and su bmitted to the
Executive Committee for transmittal, the Executive Com-
mittee should examine the extent to which the charge has
been fulfilled, the adequacy of the committee's consulta-
tion with other elements of the SAB with which there is
overlapping or spinoff concern, the clarity of the evalua-
tive logic within the review, the quality of the report as a
communication (readability, focus, contexting, documen-
tation), and plans for follow-through.
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 Administrator—should con-
tinue to be the primary recipient of EPA 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.
Recommendation on SAB Requests for Response
from the Administrator
The SAB should continue routinely to request thai tlic Admin-
istrator provide timely, written responses to formally trans-
mitted SAB advice.
Recommendation on Advising Nonheadquarters
EPA Units Directly.
The SAB should consider advising the EPA Laboratory Di-
rectors or Regional Administrators directly, but only if this is
requested by the EPA Administrator.
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.
Recommendations on SAB Agenda-Setting
• 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.
¦ The Executive Committee, actively involving the
standing-committee chairs, all of whom are Executive
Committee members, should continually scrutinize the
agenda of the Board ;is a whole so as to make the Board
most responsive and :.nost 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.
• 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 be-
tween the Board and the Agency, with every effort made
to focus on issues having the highest importance.
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
• affect overall environmental protection;
• address novel scientific problems or principles;
• integrate science into Agency actions in new ways;
• influence long-term technological development;
• respond to emergencies;
• deal with problems that pervade several EPA domains;
• address problems that transcend federal-agency or other
organizational boundaries;
• strengthen the Agency's basic capabilities:
• serve congressional or other leadership interests.
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Recommendation on Improving Timing and
Timeliness
Early in contemplated advisory exchanges, the relevant EPA
offices and SAB committees should discuss the nature of the
proposed advising; reach clear agreement on which aspects of
the subject will be examined, and how: negotiate timing,
interim reports and checks, deadlines, procedure, staffing, and
documentation needs; and carefully husband and schedule the
use of SAB talents and staff support.
Recommendation on Husbanding of Staff Efforts
Committee chairs and members should help budgeL and pro-
tect the SAB staff officers' time and efforts. Also they should
encourage their committees' executive secretaries, as impor-
tant parts of their jobs, actively to pursue liaison with the
Agency program and other offices—to cultivate vigorous
working relationships, discuss arising issues, negotiate expec-
tations for reviews, and follow through on advice rendered.
Finding on SAB Staff Office Operations
The subcommittee Finds, and has been urged by many Board
members to emphasize, that the clerical and secretarial sup-
port services are very inadequate for handling the relentless
SAB office workload of telephoning, planning meetings, ar-
ranging travel, reimbursing expenses, and preparing, revising,
logging, reproducing, and distributing large volumes of docu-
ments. Clerical performance is not uniformly impressive
(grade-level and salary limits may be a problem).
Many of the problems are the result of overload. In the past
few years turnover 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.
Recommendation on Upgrading of SAB Office
Computer Efficiency
The Board should encourage the SAB office to invest the
infrastructure! effort required to survey the capabilities of its
computers and those available to the EPA, acquire the neces-
sary software, set up mailing lists and tracking systems and
document preparation systems, train all of the staff appropri-
ately, and in general master and prepare to make the fullest
use of computers.
Finding and Recommendation on the SAB
Budget
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 care-
fully as the budget of the Agency itself.
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Appendix B—Office of Policy, Planning and E valuation
Program Evaluation Division
SAB Reinvention—Main Messages from EPA Inverviewers
Overall Message:
The familiarity and experience of agency staff with the SAB
is understandably quite diverse. Despite this diversity, the
majority of the Agency managers and staff that the PED
interviewed valued some aspect of the SAB. Additionally,
certain common messages emerged from the variety regard-
ing possible opportunities for reinventing SAB. Some of these
arc presented below. Additional issues, comments and themes
(some of which were stated with considerable frequency) are
presented in the full summary of interview data.
A. Agency interviewees believe there is too much involve
ment in policy questions/decisions by SAB members.
Approximately three quarters of the interviewees indi-
cated that it is not appropriate for SAB members to state
positions on Agency regulatory decisions.
1. SAB's mission is to provide neutral science advice.
2. Regulatory policy involvement undermines the cred-
ibility and objectivity of the SAB.
3. SAB policy involvement undermines the agency's
authority to make decisions in this arena.
4. SAB members are not public policy experts.
B. Interviewees frequently voiced concerns about the di-
versity of SAB membership, openness of the selection
process and especially strong concerns about the poten-
tial for conflict of interest between serving the Agency
as a member of the SAB and serving personal interests.
1. Concerns ranged from a general recognition of the
potential for conflict of interest to specific concerns
about individual SAB members.
2. Typical perceived conflicts: obtaining research fund-
ing; serving a private sector employer; serving an-
other government agency.
3. Additional concern: no adequate mechanism exists
to address this perception.
C. Agency managers and staff view S AB-initiated projects
as a double-edged sword.
1. SAB self-initiation is a good check and balance
system on agency science.
2. Agency managers and staff are leery of the SAB not
having the time or resources to meet Agency re-
quests due to competition from self-initiated projects.
3. Agency managers and staff are concerned about the
practical problems posed by the unexpected resource
drains/demands resulting from SAB self-initiated re-
views.
D. Interviewees commented that gaps in SAB members'
understanding of the Agency and the regulatory/statu-
tory context for reviews reduces the utility of SAB
recommendations and advice to the Agency.
1. Perception in the Agency that the SAB tends to be
more academic and out of touch with the regulatory
confines of the Agency.
2. Perceived lack of SAB appreciation for statutory and
court-ordered deadlines; the frequent need to take
action despite uncertain information.
E. Interviewees reported a lack of education/lack of com-
munication to the Agency from the SAB on matters
such as
1. The process for selecting members.
2. The process for selecting topics for review.
3. The clarification of mission and functions and how
these can help the customer.
4. The preparation and expectations for briefing.
F. The process for delivering reports to the Agency often
reported to be too slow and to not meet the Agency's
needs.
1. There is too long a delay between final briefing and
formal written report.
2. Oral comments at exit interview are helpful, but not
uniformly received.
29
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3, The SAB should state its recommendations more
clearly, using less ambiguous language,
G. Interviewees noted the utility of early advice/consulta-
tion and a desire for more options for informal interac-
tion.
1. Program offices find SAB input early in "product"
development useful.
2. SAB as "stable of experts" to offer advice to agency.
3. Caution; those who advise should not also perform
the review function.
H. Some managers and a number of Agency staff cited the
lack of response by the Agency to SAB recommenda-
tions as a problem.
1. Resource investment in SAB reviews is high, often
with little follow-up by the Agency.
2. Since the Agency is not obligated to follow the
recommendations of the SAB, the response time
from the Administrator is slow or at times nonexist-
ent
3. The Administrator's office needs to read and discuss
the reports- that come from Ihe SAB and respond in a
timely manner,
I. Many respondents (especially in ORD) expressed con-
cern over the Agency's ever-increasing demand for
peer review.
1. In sonic cases current needs for SAB advice and
review are not being met and increasing future needs
may overtax SAB.
2, Some program offices have a strong internal peer
review process, but in other programs one does not
exist,
J. Agency interviewees noted that the role of the SAB in
relation to other science advisory bodies needs to be
clarified.
1. What are the various science advisory bodies, what
are their roles, and what, if any, coordination exists
between them?
2. Who is at the helm guiding agency science?
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Appendix C
Solicitation of Answers to Questions about the SAB
Self-assessment of knowledge of SAB and its activities on a
scale of 1 to 10:
1. Perceived strengths and weaknesses
a. In your opinion, what are the greatest strengths of the
SAB:
2) Reviewing research programs
3) Reviewing the technical bases of various applied
programs
4) Advising on infrastructural and technical manage-
ment issues
5) Advising on short-notice problems
6) Advising on broad, strategic matters
1) To the Agency
2) To the public
3) To a special constituency; e.g.. the environmental
community and the business community.
b. In your opinion, what are the greatest weaknesses of the
SAB:
1) To the Agency
2) To the public
3) To a special constituency; e.g., the environmental
community and the business community.
2. View of the SAB in 1989 Self-Study
a. In its 1989 self-study the SAB identified two principal
missions:
1) An aiding-and-extending mission—e.g., providing a
forum for discussion of technical issues in which the
affected parties, the concerned public, Congress,
Agency management. Agency staff, and other agen-
cies can exchange views on technical matters.
2) An auditing-and-certifying mission—e.g., reviewing
technical documents from the Agency.
Please comment on the appropriateness of these mis-
sions and their relative importance from your per-
spective. Also, suggest any additional missions(s)
that you would like to sec added to the SAB.
b. In its 1989 self-study the SAB identified six specific
functions:
1) Reviewing the quality and relevance of particular
regulatory science
Please comment on the appropriateness of these mis-
sions and their relative importance, from your per-
spective. Also, suggest any additional function(s)
that you would like to see added to the SAB.
3. SAB Activities
a. Process for selecting issues for attention by the SAB.
The Board currently identifies the set of issues for atten-
tion through a negotiating process involving the Execu-
tive Committee, the individual committees, the Agency
program offices, and the Administrator/Assistant
Administrator's offices.
What arc the strengths and weaknesses of the process and
how could it be improved?
b. SAB involvement in "policy issues."
In recent years considerable attention has focused on the
propriety of the SAB's getting involved in what some
perceive as "policy issues." Some would cite the Board's
Reducing Risk report on the comparison between differ-
ent environmental risks as such an issue. Others would
point to the unsolicited commentary from the Board that
called the Administrator's attention to what they viewed
as a disproportionate Agency response to the risk of
radon gas in drinking water vs. the risk of radon gas in
home basements.
Please comment on the extent to which the SAB should
comment on policy implications of its technical findings.
Try to illustrate your comment with examples of appro-
priate and inappropriate issues.
31
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4. Timeliness
The Board currently provides advice to the Agency through
formal reports that are approved by the Executive Com-
mittee and transmitted to the Administrator, This process
is time-consuming—although, on average, less than 6
months passes between the last committee public meeting
and transmittal of the final report to the Administrator.
Are there alternative routes, or even alternative modes of
advice, that should be considered?
5. Membership
The current membership selection process involves pub-
lic solicitation of nominees, coupled with targeted searches
and discussions with key groups; e.g., SAB committees.
The final selection is made by the Administrator.
What are the strengths and weaknesses of the process and
how could it be improved?
6. Structure
The Board's ten committees evolved over time.
Clean Air Act Compliance Analysis Council (CAACAC)
Clean Air Scientific Advisory Committee (CASAC)
Drinking Water Committee (DWC)
Ecological Processes and Effects Committee (EPEC)
Environmental Economics Advisory Committee (EEAC)
Environmental Engineering Committee (EEC)
Environmental Health Committee (EHC)
Indoor Air Quality/Total Human Exposure Committee
(IAQC)
Radiation Advisory Committee (RAC)
Research Strategic Advisory Committee (RSAC)
Some of them reflect Agency programs (e.g., CASAC
and DWC); others cut across the Agency (e.g., EEAC and
RSAC).
There are related technical advisory activities being car-
ried out by other groups within EPA; e.g., the FIFRA
Scientific Advisory Panel and the Biotechnology Scien-
tific Advisory Committee.
Is there a better way to organize the Board and/or related
groups to provide technical advice to the Agency more
effectively and efficiently?
7. Agency- vs. Self-initiated Activity
Some people believe that the SAB serves the Agency best
by being available to advise the Agency when asked to do
so. Others maintain that the SAB serves the Agency best
by actively examining issues on its own and providing
unsolicited advice.
What mix of the two modes of action is best; e.g.,
50%-50%, 10%-90%?
8. General Solicitation of Comment oil the
Board
In addition to responses to the questions above, the
committee welcomes thoughtful comment on any and all
aspects of the Board and how it might be reinvented to
accomplish its purposes more efficiently and effectively.
32
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Appendix D
Extra-Agency Interviewees
1. Political appointees 2.
Erich Bretthauer
Former AA/ORD
Don Clay
Former AA/OPTS
Former AA/OAR
Former AA/OSWER
Terry Davies
Former AA/OPPE
Linda Fisher
Former AA/OPTS
Former AA/OPPE
John A. Moore
Former Acting Administrator
Former Deputy Administrator
Former AA/OPTS
William Ruckelshaus
Former Administrator
Business, Academic, and Environmental
Communities
Dr. Theo Colburr
World Wildli fe Fund
Dr. Rob Coppock
World Resources Institute
Dr. Michael Gough
Office of Technology Assessment
Dr. Robert J. Graham
Harvard School of Public Health
Mr. Peter Barton
Hutt Covinglon & Burling
Mr. William F. O'Keefe
American Petroleum Institute
Dr. I. Rosenthal
University of Pennsylvania
Dr. Terry Thoem
Conoco, Inc.
Ms. Victoria J. Tshinkel
Landers & Parsons
Dr. Ron White
America Lung Association
Representatives of Other Agencies
Dr. Bany Johnson
Agency for Toxic Substances
and Disease Registry
33
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Appendix E
Draft Description ot'ad hoc Subcommittee to
Develop Guidelines on Selection of SAB Projects
Mission
To develop precise, clear, and casy-to-implement criteria for
selecting projects (i.e., full review, self initiated, commentar-
ies, and consultations) for SAB review/advice. Factors such as
timeliness, expected impacts crosscutting issues and added
value to the Agency/public may be included in the criteria for
selection of projects. Guidelines containing the identified
criteria and how to use them for selection of SAB projects
should be the end product to be delivered by this ad hoc.
committee. This committee should also develop recommen-
dations as to who should choose projects using the guidelines
(i.e., a permanent subcommittee, standing committees indi-
vidually, Executive Committee) and when such choices should
be made. Flexibility should be maintained.
Duration
This committee should complete its mission within a six-
month period.
Composition
There should be two members from the Executive Committee,
two to three members from the standing committees, and one
member from the Office of the SAB.
34
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Appendix F
Draft Position Paper on Science/Policy Interface
Science and policy are bolh multifacctcd subjects, and in the
context of the EPA's work they can interface in many ways,
interpenetrating each other. While there is a "core" of each in
which one is clearly recognized as "science" and the other as
"policy," science and its use in (he context of a regulatory
agency is seldom free of policy implications, whereas policy,
in the same context, often has scientific implications.
The SAB has traditionally tried to avoid deliberate entry into
areas that clearly involve policy or policy making: on the
occasions where this has been necessary, the SAB has been at
pains to so note and to offer its reasons for doing so. The SAB
has seen science (and technology) as its proper sphere, but, in
recognition of the close relation between science and policy
described earlier—and of the fact that, with advent of the
EEAC, the work of the SAB has moved closer to core policy
area—it is necessary to define the SAB's relation to policy.
The fact that science and policy usually influence each other
should not deter the SAB from its basic mission. That mission
is to ensure—to the best of the Board's collective knowledge
and judgment—that the science conducted and used by the
Agency is as well and as credibly conducted and used as it can
be and that its uncertainties and alternatives are amply consid-
ered and addressed.
Commenting on important scientific disparities among poli-
cies, noting instances where science weakens or contradicts
policy, commenting on cases where science has been badly
used in formulating policy or in which policies may have
adverse effects on the conduct or use of science are within the
capabilities of the SAB arid should fall within the bounds of
the SAB's role. In these liases, the SAB should make clear
what it is doing and why it is doing iL
In instances in which the SAB is specifically requested to
provide policy suggestions or proposals by the Agency, the
SAB, if it believes it can do justice to the request, can accede
to the request, but this request must be clearly contained in the
charge.
In no case should the SAB go into detail on the implementa-
tion of policy, although it can analyze and comment on the
scientific support for, or the scientific implications of such
implementation. Also, the SAB should not, gratuitously and
on its own, propose or make policy or policy suggestions to
the Agency.
35
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Appendix G
Affiliation with the Science Advisory Board
1. Types of Participants: Members and
Consultants
Members are nongovernment employees who serve on the
SAB through appointment by the EPA Administrator,
normally for a two-year term (renewable twice for a total
of up to six years). Should a member be appointed to a
two-year term as a committee chair, he/she may be reap-
pointed to that post once.
Members are compensated for their time unless they elect to
serve without compensation (WOC). Their travel and per
diem expenses are paid.
Members are subject to conflict-of-interest laws (excepting
representatives) and fill out all personnel paperwork.
Although the Board generally operates through consensus,
only members may participate in any votes on an issue.
Technically, members may be special government employ-
ees (SGEs) or representatives (see below), although it is
generally expected that an SAB member will serve as an
SGE.
Consultants are nongovernment employees who serve on
the SAB through appointment by the SAB staff director
for a one-year term, renewable annually until such time
that their expertise is no longer needed or they elect to
terminate affiliation with the Board. Consultants do not
serve as committee chairs.
Consultants arc compensated for their time unless they elect
to serve WOC. Their travel and per diem expenses are
paid.
Consultants (excepting those serving as representatives) are
subject to conflict-of-interest laws and fill out all person-
nel paperwork.
The Board generally operates through consensus, but in the
event of a vote on an issue, consultants do not participate.
Technically, consultants may be SGEs or representatives
(see below), although it is generally expected that an
SAB member will serve as an SGE.
2. Status of M/Cs: SGEs and
Representatives
SGEs are nonfederal government employees who enter inter-
mittent federal, service through a personnel appointment (initi-
ated by SAB staff using an SF-52). They are normally
compensated for their time unless they elect to serve WOC.
Their travel and per diem expenses are paid. They are subject
to conflict-of-interest laws, fill out all personnel paperwork,
and arc subject to certain post-employment restrictions after
leaving the Board.
Representatives are nonfederal government employees who
serve on the SAB, but whose economic interests cannot be
fully separated from those of their employer. They arc not
compensated for their time, and travel and per diem expenses
may be covered by either their employer or EPA. They arc not
subject to the financial disclosure or conflict-of-interest laws.
They do not fill out any personnel paperwork. A representa-
tive is asked to serve on the SAB because a) the Board would
likely benefit from hearing the technical views of the em-
ployee and/or b) his/her employer would not allow the indi-
vidual to participate in any other way. In some instances,
service as an SGE can limit subsequent activities of that
expert in future dealing with the Agency on the matter.
3. Other Participants: Federal Liaisons,
Invited Experts, and Invited
Participants
Federal Liaisons are federal employees who are invited to
participate in SAB reviews because of their particular exper-
tise in or perspective on the technical issue being discussed.
Their service is limited to the duration of the committee's
consideration of that issue. They are not compensated for their
time; however, travel and per diem expenses may be paid. An
SF-52 is not processed and no paperwork other than a travel
authorization is prepared in those cases in which SAB pays
for the travel. They are subject to their own agency's conflict-
of-interest regulations, which are comparable to EPA's. Con-
sequently, they do not file a separate SF-450 (confidential
financial form) with the SAB. However, they are expected to
participate in the formal conflict-of-intcrcst disclosure at the
beginning of SAB meetings.
Invited Experts are individuals brought to a meeting at SAB
expense to provide technical information and insights. They
are not a part of the SAB panel and receive no compensation
for their time. Therefore, they are not subject to paperwork
36
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obligations beyond travel arrangements (invitational travel)
and vouchers.
Invited Participants are individuals designated as SAB mem-
bers or consultants whose appointment paperwork has not
been completed. They are designated as such on the travel
authorization and are reimbjrscd for travel expenses. How-
ever, they cannot be compensated for their time until the
personnel action (SF-50) has been completed. They may
not participate in the meeting unless their SF-450 (confi-
dential financial form) has been completed.
37
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Appendix H
Glossary of Terms and Acronyms
AAs
Assistant Administrators
ATSDR
Agency for Toxic Substances and Disease Registry
CAA
Clean Air Act
CAACAC
Clean Air Act Compliance Analysis Council
COM
Commentary
DFO
Designated Federal Official
DWC
Drinking Water Committee
EC
Executive Committee of the SAB
EEAC
Environmental Economics Advisory Committee
EEC
Environmental Engineering Committee
EPA
Environmental Protection Agency
EPEC
Environmental Processes and Effects Committee
ERDAA
Environmental Research and Development Authorization Act
ESEAC
Environmental Socioeconomic Advisory Committee
FDA
Food and Drag Administration
FIFRA
Federal Insecticide, Fungicide and Rodenticide Act
FR
Federal Register
FY
Fiscal Year
IAQC
Indoor Air Quality/Total Human Exposure Committee
ISBN
International Standards of Book Numbers
MAF
Mission and Functioning
M&O
Mission and Organization
OGC
Office of General Counsel
OPPE
Office of Policy, Planning and Evaluation
OPPT
Office of Pollution Prevention and Toxics
OPPTS
Office of Prevention, Pesticides and Toxic Substances
OPTS
Office of Pesticides and Toxic Substances
ORD
Office of Research and Development
OSAB
Office of Science Advisory Board
OSWER
Office of Solid Waste and Emergency Response
PED
Program Evaluation Division
RAs
Regional Administrators
38
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Glossary of Terms and Acronyms
RAC Radiation Advisory Committee
RC RcinvcnLion Committee
RCRA Resource Conservation and Recovery Act
RIA Regulatory Input Analysis
RSAC Research Strategies Advisory Committee
SAB Science Advisory Board
SAP Scientific Advisory Panel
SPC Science Policy Council
TQM Total Quality Management
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