• A v
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
September 11, 2013
Why We Did This Review
The U.S. Environmental
Protection Agency Office of
Inspector General conducted this
review in response to a
congressional request about the
EPA's management of the Clean
Air Scientific Advisory Committee
and the Advisory Council on
Clean Air Compliance Analysis.
We sought to determine whether
the EPA has managed the
CASAC and Council in
accordance with applicable laws,
regulations and guidance
pertaining to (1) potential conflicts
of interest, (2) appearances of a
lack of impartiality, (3) rotation of
members (i.e., term limits),
(4)	balance of committee
viewpoints and perspectives and
(5)	peer review. The EPA's
Science Advisory Board Staff
Office manages the CASAC and
Council, which provide advice to
the EPA on setting air quality
standards and in developing
cost-benefit analyses of the
Clean Air Act.
This report addresses the
following EPA Goals or
Cross-Cutting Strategies:
•	Taking action on climate and
improving air quality.
•	Advancing science, research,
and technological innovation.
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
EPA Can Better Document Resolution of Ethics and Partiality
Concerns in Managing Clean Air Federal Advisory Committees
What We Found
In general, the EPA managed the CASAC and Council in accordance with
applicable statutes and regulations. These regulations allow agencies discretion
in choosing federal advisory committee members and achieving balance.
We reviewed 47 CASAC and Council member appointments, including all
ozone panel appointments for the last two ozone standard reviews. We found
that the EPA has adequate procedures for identifying potential ethics concerns,
including financial conflicts of interest, independence issues and appearances
of a lack of impartiality. However, the EPA can better document its decisions on
selecting members with independence and partiality concerns. This would allow
for better transparency, thus giving assurance that CASAC and the Council
provide independent and objective advice to the Administrator on such
important decisions as setting ambient air standards. We also identified one
instance where agency procedures involving a potential conflict of interest were
not followed.
We also reviewed the peer review process for three EPA-developed analyses
included in scientific assessments peer reviewed by the CASAC. Peer review
is one method for enhancing the quality and credibility of the government's
scientific information. One of these analyses was not peer reviewed in
accordance with Office of Management and Budget and agency guidance.
The EPA's National Center for Environmental Assessment did not have a
formal process for determining whether such analyses were subject to OMB
requirements and the EPA's peer review guidance before public dissemination.
Recommendations and Planned Corrective Actions
We recommend that the EPA instruct staff on the proper process for addressing
potential conflicts of interest, develop procedures to document decisions and
mitigating actions regarding independence and partiality concerns, and
implement a process to determine whether its scientific work products are
influential scientific information that require peer review in accordance with
OMB and the EPA's guidance. The agency completed corrective action for one
recommendation and that recommendation is closed. The agency agreed with
three other recommendations and provided corrective action plans that we
accepted. The agency disagreed with one recommendation but proposed an
alternative action that we accepted. Thus, four recommendations are resolved
but open pending completion of the corrective actions.
Noteworthy Achievements
Although not required, the EPA applies many Federal Advisory Committee Act
guidelines and procedures to managing subcommittees and panels.