Scientific
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Policy
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www.epa.gov/scientificintegrity

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The following is a full-length, "pocket-sized" version
of the U.S. Environmental Protection Agency Scientific
Integrity Policy. The Scientific Integrity Committee and
the Science Advisor periodically approve the updates to
the 2012 Policy.

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U.S. EPA
Scientific Integrity
Policy
I.	Purpose
The Agency has established, and continues to promote, a
culture of scientific integrity for all of its employees. This
policy provides a framework intended to ensure scientific
integrity throughout the EPA and promote scientific and ethical
standards, including quality standards; communications with
the public; the use of peer review and advisory committees;
and professional development. It also describes the scope and
role of a standing committee of Agency-wide scientific integrity
officials to implement this policy.
II.	Background
Science is the backbone of the EPA's decision-making.1 The
Agency's ability to pursue its mission to protect human health
and the environment depends upon the integrity of the science
on which it relies. The environmental policies, decisions,
guidance, and regulations that impact the lives of all Americans
every day must be grounded, at a most fundamental level, in
sound, high quality science. When dealing with science, it is the
responsibility of every EPA employee to conduct, utilize, and
communicate science with honesty, integrity, and transparency,
both within and outside the Agency. To operate an effective
science and regulatory agency like the EPA, it is also essential
that political or other officials not suppress or alter scientific
findings.
At the EPA, promoting a culture of scientific integrity is closely
linked to transparency. The Agency remains committed to
transparency in its interactions with all members of the public.
These values were first expressed in then Administrator
William Ruckelshaus' "Fishbowl Memo" (19 May 1983) [1], This
memorandum established a culture of integrity and openness
for all employees by promising the EPA would operate "in a
fishbowl" and "will attempt to communicate with everyone
1 In this document, "science" and "scientific" are expansive terms that refer to
the full spectrum of scientific endeavors, e.g., basic science, applied science,
engineering, technology, economics, social sciences, and statistics. The term
"scientist" refers to anyone who collects, generates, uses, or evaluates scientific
data, analyses, or products.
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from the environmentalists to those we regulate, and we will do
so as openly as possible."
This Scientific Integrity Policy builds upon existing Agency
and government-wide policies and guidance documents,
enhancing the EPA's overall commitment to scientific integrity.
This commitment is evidenced by the Agency's adherence to
the 2002 Office of Management and Budget (OMB) Information
Quality Guidelines [2], the 2005 OMB Information Quality
Bulletin for Peer Review [3], the EPA's Quality Policy [4]
for assuring the collection and use of sound scientific data
and information, the EPA's Peer Review Handbook [5] for
internal and external review of scientific products, and the
EPA's Information Quality Guidelines [6] for establishing the
transparency, integrity, and utility of information published on
the Agency's websites.
The Agency has appointed a Scientific Integrity Official to
champion scientific integrity throughout the Agency. The
Scientific Integrity Official chairs a standing committee of
Deputy Scientific Integrity Officials representing each EPA
Program Office and Region2. These senior-level employees
provide oversight for the implementation of the Scientific
Integrity Policy at the EPA, act as liaisons for their respective
Programs and Regions, and are available to address any
questions or concerns regarding this policy.
III. Policy Applicability
As of the effective date, all Agency employees, including
scientists, managers, and political appointees, are required to
follow this policy when engaging in, supervising, managing, or
influencing scientific activities; communicating information
in an official capacity about Agency scientific activities; and
utilizing scientific information in making Agency policy or
management decisions. In addition, all contractors, grantees3,
collaborators and student volunteers of the Agency who engage
in scientific activities are expected to uphold the standards
established by this policy and may be required to do so as part
of their respective agreements with the EPA.4
2	The Scientific Integrity Committee Charter can be found at: https://www.epa.
gov/osa/basic-information-about-scientific-integrity
3	Language about Grantees can be found at: https://www.epa.gov/grants/
epa-general-terms-and-conditions-effective-october-1-2018
4	In addition, the EPA often uses existing data and information generated by
third parties to inform its decisions. The EPA's Information Quality Guidelines
requires the quality and scientific soundness of this type of data to be reviewed
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This policy is created against a complicated regulatory
backdrop; it is intended to guide Agency activities in an area
that is already subject to a number of rules and policies for
various purposes. When there is overlap with other applicable
rules and guidance, this policy is not intended to preempt
other authorities, but instead to work in conjunction with
and supplement them. This policy is intended to improve the
internal management and operation of the Agency. It does not
create any obligation, right or benefit for any member of the
public, substantive or procedural, enforceable by law or in
equity by any party against the United States, its departments,
agencies, or entities, its officers, employees or agents, or any
other person.
Actions taken in accordance with this policy are subject to the
availability of appropriated funds, and must be authorized
under and consistent with existing authorities, including
applicable law and regulations, Executive Orders, and Federal
and EPA ethics, information, and personnel rules and policies.
This policy does not limit the legal requirements contained in
the Standards of Ethical Conduct for Employees of the Executive
Branch (5 C.F.R. 2635), EPA Supplemental Standards of Ethical
Conduct (5 C.F.R. 6401), any of the criminal conflict of interest
statutes (18 U.S.C. 201-209), the Hatch Act (5 U.S.C. 7321 -
7326) or its implementing regulations (5 C.F.R. 734), or law
enforcement actions and/or investigations and inspections for
regulatory compliance. Special attention should also be given to
the EPA clearance procedures5 and compliance with the Privacy
Act (5 U.S.C. 552a) and the Freedom of Information Act (FOIA),
5 U.S.C. 552.
IV. Scientific Integrity Policy
The Agency has long fostered a culture of scientific integrity
through its Principles of Scientific Integrity [8], These
principles were developed in 1999 in conjunction with the
EPA's National Partnership Council (NPC), a partnership of
Agency labor unions and management. The Principles of
Scientific Integrity sets forth the Agency's commitment to
5 CFR 2635.702(b) provides "an employee shall not use or permit the use of
his Government position or title or any authority associated with his public
office in a manner that could reasonably be construed to imply that his agency
or the government sanctions or endorses his personal activities or those of
another." See also 5 CFR 2635.807(b) for more specific requirements related
to uncompensated teaching, speaking, and writing. Section 807(b)(1) provides
that an employee "may include or permit the inclusion of his title or position as
one of several biographical details when such information is given to identify
him ... provided his title is given no more prominence than other significant
biograpnical details." It should be clearly understood that, except as permitted
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conducting science objectively, presenting results fairly and
accurately and avoiding conflicts of interest.
Consistent with the EPA's Principles of Scientific Integrity the
Agency's Scientific Integrity Policy reaffirms the expectation
that all Agency employees, including scientists, managers,
and political appointees, regardless of grade level, position, or
duties:
•	Ensure that the Agency's scientific work is of the highest
quality, free from political interference or personal
motivations.
•	Represent his/her own work fairly and accurately6.
•	Appropriately characterize, convey, and acknowledge the
intellectual contributions of others.
•	Avoid conflicts of interest and ensure impartiality.
•	Be cognizant of and understand the specific programmatic
statutes that guide their work.
•	Welcome differing views and opinions on scientific and
technical matters as a legitimate and necessary part of the
scientific process.
•	Accept the affirmative responsibility to report any breach of
this Scientific Integrity Policy.
To promote scientific integrity throughout the Agency, this
policy outlines four specific areas: a) the culture of scientific
integrity at the EPA, b] public communications, c] the use
of peer review and Federal Advisory Committees, and d]
professional development of government scientists. In addition,
the policy establishes the Scientific Integrity Committee,
chaired by the Agency's Scientific Integrity Official, to
implement this policy.
A. Promoting a Culture of Scientific Integrity at the EPA
Successful application of science in Agency policy decisions
relies on the integrity of the scientific process both to
ensure the validity of scientific information and to engender
public trust in the Agency. Thus, it is essential that the EPA's
policymakers involve science experts on scientific issues and
that the scientific information and processes relied upon in
policymaking manifest scientific integrity, quality, rigor, and
objectivity. The Agency reaffirms and promotes scientific
integrity across the EPA by supporting the culture of scientific
by 5 C.F.R. 2635.807(a)(3), an employee may not receive compensation from
any source other than the Government for teaching, speaking, or writing that
relates to the employee's official duties [7],
6 See "Best Practices for Designating Authorship" https://www.epa.gov/osa/
authorship-best-practices
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integrity, enhancing transparency within scientific processes,
and protecting Agency scientists.
1. To support a culture of scientific integrity within the Agency,
this policy:
a.	Promotes a culture of scientific integrity, fostering honest
investigation, open discussion, refined understanding, and
a firm commitment to evidence.
b.	Requires adherence to applicable Agency information
quality, quality assurance, and peer review policies and
procedures, ensuring that the Agency produces scientific
products of the highest quality, rigor, and objectivity for use
in policy decisions.
c.	Recognizes the distinction between scientific information,
analyses, and results from the policy decisions made based
on that scientific information; policy makers within the
Agency weigh the best available science, along with
additional factors such as practicality, economics, and
societal impact, when making policy decisions.
d.	Prohibits all EPA employees, including scientists, managers,
and other Agency leadership, from suppressing, altering, or
otherwise impeding the timely7 release of scientific findings
or conclusions.
e.	Encourages the use of the FOIA framework to promote
accountability. If a response to a FOIA request related to
scientific information is overdue, the requester may continue
contacting the assigned lead office or the FOIA Public
Liaison, or he or she may also file a timeliness allegation
with the Scientific Integrity Official.
f.	Requires all Agency employees to act honestly and refrain
from acts of scientific misconduct. Scientific misconduct
includes fabrication, falsification, or plagiarism in proposing,
performing, or reviewing scientific and research activities, or
in the publication or reporting of these activities; scientific
misconduct does not include honest error or differences of
opinion. Scientific misconduct is normally adjudicated by the
Office of Inspector General8. The OIG has agreed to allow the
Scientific Integrity Official to evaluate allegations of
plagiarism (except in the circumstances listed in EPA Order
3120.5, Section 7), including making inquiries and writing
7	The Agency has defined timely at: https://www.epa.gov/sites/production/
files/2016-10/documents/scientific_integrity _timeliness_policy.pdf
8	Coordination Procedures between the Scientific Integrity Official and the
Office of Inspector General can be found here: https://www.epa.gov/osa/co-
ordination-procedures-between-scientific-integrity-official-and-office-in spec-
tor-general
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reports summarizing the findings of those inquiries.
g.	Requires adherence to Agency documents that address the
use and characterization of scientific information in Agency
policy development, such as EPA's Action Development
Process [9], the EPA's Guidance for Risk Characterization
[10] and Risk Characterization Handbook [11],
h.	Recognizes that while Agency risk assessments are intended
to address the needs of risk management, quantitative
conclusions should not be influenced by possible risk
management implications of the results.
2. To enhance transparency within Agency scientific processes,
this policy:
a.	Requires reviews by Agency managers and other Agency
leadership regarding the content of a scientific product to
be based only on scientific quality considerations, e.g., the
methods used are clear and appropriate, the presentation of
results and conclusions is impartial.
b.	Ensures scientific findings are generated and disseminated
in a timely and transparent manner, including scientific
research performed by contractors, grantees, or other
Agency partners who assist with developing or applying the
results of scientific activities.
c.	Establishes the expectation that when communicating
scientific findings, Agency employees include a
clear explication of underlying assumptions, accurate
contextualization of uncertainties, and a description of the
probabilities associated with both optimistic and pessimistic
projections, if applicable.
d.	Strengthens the actual and perceived credibility of Agency
science by, e.g., ensuring that the selection of candidates for
scientific positions is based primarily on their scientific and
technological knowledge, credentials, experience, and
integrity; ensuring that scientific studies used to support
regulatory and other policy decisions undergo appropriate
levels of independent peer review; setting clear standards
governing conflicts of interest; and adopting appropriate
whistleblower protections.
e.	Recognizes the value of independent validation of scientific
methods.
f.	Recognizes the value of independent review of the Agency
scientific facilities and testing activities, as occurs with
accreditation by a nationally or internationally recognized
sanctioning body and as required by Agency policy directives
[12]-
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g. Facilitates the free flow of scientific information. The Agency
will continue to expand and promote access to scientific
information by making it available online in open formats in
a timely manner, including access to data and non-
proprietary models underlying Agency policy decisions.
Further, the use of non-proprietary data and models are
encouraged, when feasible, to increase transparency.
3. To assure the protection of Agency scientists, this policy:
a.	Prohibits managers and other Agency leadership from
intimidating or coercing scientists to alter scientific
data, findings, or professional opinions or inappropriately
influencing scientific advisory boards. In addition, policy
makers shall not knowingly misrepresent, exaggerate, or
downplay areas of scientific uncertainty associated with
policy decisions.
b.	Mandates the Scientific Integrity Official, with input from the
Deputy Scientific Integrity Officials, to develop a transparent
mechanism for Agency employees to express differing
scientific opinions. When an Agency employee substantively
engaged in the science informing an Agency policy decision
disagrees with the scientific data, scientific interpretations,
or scientific conclusions that will be relied upon for said
Agency decision, the employee is encouraged to express that
opinion, complete with rationale, preferably in writing. It is
expected that any differing scientific opinions will be
resolved during internal deliberations and if not, will be
addressed during scientific peer review. The report from the
peer review panel will be made available for the policy
makers' consideration. When no peer review occurs,
differing scientific opinions will be reflected in the Agency's
deliberative documents for the policy makers'
consideration.9
c.	Extends whistleblower protections [13] to all EPA employees
who uncover or report allegations of scientific and research
misconduct, or who express a differing scientific opinion,
from retaliation or other punitive actions. Employees who
have allegedly engaged in scientific or research misconduct
will be afforded the due process protections provided by law,
regulation, and applicable collective bargaining agreements,
prior to any Agency action. All Agency employees should be
familiar with these protections and avoid the appearance of
retaliatory actions. In 2012, the U.S. Congress passed the
Whistleblower Protection Enhancement Act amending the
9 The Agency's "Approachesfor Expressing and Resolving Differing Scientific
Opinions" can be round at: https://www.epa.gov/osa/diftering-scientific-opinions
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Whistleblower Protection Act of 1989 and strengthening
protections for federal employees and applicants for federal
employment.10
d. Notes that, in 2002, the U.S. Congress passed the Notification
and Federal Employee Antidiscrimination and Retaliation
Act ("No FEAR Act") to promote a federal work environment
that is free of discrimination and retaliation.11
B. Release of Scientific Information to the Public
Scientific research and analysis comprise the foundation
of all major EPA policy decisions. Therefore, the Agency
should maintain vigilance toward ensuring that scientific
research and results are presented openly and with integrity,
accuracy, timeliness, and the full public scrutiny demanded
when developing sound, high-quality environmental science.
This policy is intended to outline the Agency's expectations
for developing and communicating scientific information to
the public, to the scientific community, to Congress, and to
the news media by further providing for and protecting the
EPA's longstanding commitment to the timely and unfiltered
dissemination of its scientific information - uncompromised
by political or other interference. This policy recognizes the
importance of, and the need to foster a culture of, openness
regarding the results of research, scientific activities, and
technical findings. To that end, the EPA strongly encourages
and supports transparency and active, open communications
through various forms including, but not limited to, publication
in peer-reviewed or refereed journals, conference papers and
presentations, media interviews, responses to Congressional
inquiries, web postings, and news releases.
Full and open communication is a shared responsibility
throughout the Agency. To fulfill this shared responsibility,
the following describes both what is expected of the EPA's
employees and what they, in turn, can expect from others in the
Agency.
10	Section 110 of the Act clarifies that whistleblower protections may be avail-
able for employees or applicants for employment who disclose information that
they reasonably believe is evidence of censorship related to research, analysis,
or technical information. The term "censorship related to research, analysis, or
technical information" is defined to mean any effort to distort, misrepresent, or
suppress research, analysis or technical information. Disclosures may be pro-
tected if the individual reasonably believes that the censorship is or will cause
a violation of law, rule, or regulation; gross mismanagement, a gross waste
of funds, an abuse of authority, or a substantial and specific danger to public
health or safety, https://www.gpo.gov/fdsys/pkg/
PLAW-112publl99/pdf/PLAW-112p ubll99.pdf
11	https://www.epa.gov/ocr/whistleblower-protections-epa-and-how-they-re-
late-non-aisclosure-agreements-signed-epa-employees
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1. EPA Scientists and Managers
The Agency's scientists and managers are expected to:
a.	Represent Agency scientific activities clearly accurately
honestly objectively thoroughly without political or
other interference, and in a timely manner, consistent with
their official responsibilities. While a scientist's primary
responsibility is to pursue their scientific activities, it is also
a scientist and his/her manager's responsibility to provide
timely responses to requests for information by the media,
the public, and the scientific community.
b.	Freely exercise their right to express their personal views
provided they specify that they are not speaking on behalf
of, or as a representative of, the Agency but rather in their
private capacity. Scientists and managers must clearly
identify that the information represents their views and not
necessarily those of the EPA and use the following disclaimer
language when presenting scientific information on matters
that do not reflect their official Agency scientific activities
and direct responsibilities:
The views expressed in this [article/chapter/paper/
speech] are those of the author(s) and do not necessarily
reflect the views or policies of the U.S.
Environmental Protection Agency.
c.	Notify their managers when communicating in an official
Agency capacity. Outreach activities and media interactions
are expected to adhere to Agency ethics regulations [14] and
clearance procedures associated with ensuring accuracy and
disseminating scientific information and scientific
assessments. Scientists and managers are also expected
to notify and coordinate with appropriate Agency offices
that might receive public inquiries to ensure that scientific
information for the general public and media is clearly,
comprehensively, consistently, and accurately presented and
explained.
d.	Be available to answer inquiries from the news media
regarding their scientific work. If the scientist or manager
is unwilling or unable to communicate directly with the
news media, he/she should still provide timely assistance to
the public affairs office to help prepare and approve full and
accurate responses to media inquiries.
e.	Review, correct, and approve the scientific content of any
proposed Agency document intended for public
dissemination that significantly relies on their research,
identifies them as an author, or represents their scientific
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opinion. Disputes associated with the dissemination plan for
a scientific product will be resolved first by the employees'
direct supervisors, and if necessary the Office of Public
Affairs [OPA] and the Deputy Scientific Integrity Official or
his/her designee.
2.	Policy Officials
a. Public and media questions about any policy implications
raised by scientific studies should be addressed by
designated Agency officials responsible for conveying
information about EPA policy matters, such as program
policy experts or designated spokespersons.
3.	Public Affairs Staff
a.	Agency public affairs staff, with input from program
managers, will designate knowledgeable and articulate
spokespersons from Regional, Program, or HQ offices to
coordinate with EPA scientists and managers for the
purpose of ensuring that Agency research is clearly,
accurately, and accessibly presented, in a timely manner,
thereby best serving the needs of the media and the public.
b.	Under no circumstances should the public affairs staff
attempt to alter or change scientific findings or results. The
role of the public affairs officer is to ensure that the science
is plainly and clearly communicated for the intended
audience in a timely fashion.
c.	The public affairs staff from Regional, Program or HQ offices
should attend interviews with members of the media, when
possible, to ensure that the Agency is being fully responsive
to media questions in a timely manner and to ensure
responsiveness, consistency, and accuracy both on the part
of the interviewer and when responding to future
information requests.
d.	Members of the public affairs staff from Regional, Program,
or HQ offices must alert and coordinate with involved
scientists and managers when the public affairs staff
receives media inquiries about their research or other
scientific activities.
e.	During a nationally significant incident or environmental
crisis, OPA may officially activate or follow the EPA
National Approach to Response Crisis Communications Plan
[15]. During such episodes, this plan establishes the EPA's
process for communicating critical environmental
information to the public and for coordinating public
information among EPA field operations, Regional Offices,
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and Headquarters. Under the plan, OPA has the
communication lead for coordinating and publicly
disseminating pertinent information. OPA will closely
coordinate with involved Agency scientists to ensure the
accuracy of any Agency scientific information to be issued
by the EPA.
4. Congressional Relations Staff
a.	Office of Congressional and Intergovernmental Relations
(OCIR] staff members are expected to coordinate with
Agency scientists and managers to ensure that
Congressional inquiries regarding EPA science receive
prompt, accurate, and responsive answers.
b.	If testifying before Congress in their official capacity (i.e.,
on behalf of the EPA), scientists and managers should review
prepared testimony with OCIR staff and communicate on
matters associated with their work or area(s] of expertise in
an accurate and clearly understandable manner.
c.	Senior management in the Congressional and Program/
Regional Offices will provide any statements needed to
address policy-related questions.
C. Peer Review and the Use of Federal Advisory Committees
1. Peer Review
Independent peer review of Agency science is a crucial aspect
of scientific integrity. To ensure that scientific products undergo
appropriate peer review by qualified experts, the EPA relies
on its Peer Review Policy [16] and Peer Review Handbook [5],
The Peer Review Handbook is a how-to manual used by Agency
staff. Agency-wide peer review policies have been in place since
1993 and establish the EPA's policy for peer review of scientific
work products, including economic and social science products,
that are intended to inform Agency decisions. The handbook
includes specific expectations for categories of scientific
products, including influential scientific information (ISI] and
highly influential scientific assessments [HISA], In compliance
with OMB's 2004 Final Information Quality Bulletin for Peer
Review, the EPA posts a Peer Review Agenda [18] for its ISIs
and HISAs. In addition, the Peer Review Handbook provides
clarity for the regulatory definition of "appearance of a lack
of impartiality" [32] for individuals who serve on peer review
panels, criteria for applying this definition, and illustrative
examples.
The Agency's quality and peer review programs are further
supported by its Summary of General Assessment Factors for
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Evaluating the Quality of Scientific and Technical Information
[20],	This document describes the assessment factors and
considerations used by the Agency to evaluate the quality
and relevance of scientific and technical information. These
assessment factors are founded in guidelines, practices, and
procedures that constitute the EPA's information and quality
systems, including existing program-specific quality assurance
policies.
2. Federal Advisory Committees
The Peer Review Handbook describes the range of peer review
options, from individual letter reviews from outside experts
to large, formal reviews by Federal Advisory Committees
(FACs) or the National Academy of Sciences. Federal Advisory
Committees are an important tool within the EPA for ensuring
the credibility and quality of Agency science, enhancing
the transparency of the peer review process, and providing
for input from the EPA's diverse customers, partners, and
stakeholders. In almost all cases, FACs meet and deliberate
in public and materials prepared by or for the FAC are
available to the public. Consistent with the requirements
of the Federal Advisory Committee Act (5 USC Appendix 2)
[21],	implementing regulations from the General Services
Administration (41 CFR Part 102-3) [22], and guidance that
lobbyists not serve on FACs [23], the EPA's scientific or technical
FACs are expected to adhere to the following procedures12:
a.	Transparent recruitment of new FAC members should be
conducted through broad-based vacancy announcements,
including publication in the Federal Register, with an
invitation for the public to recommend individuals for
consideration and submit self-nominations.
b.	Professional biographical information (including current
and past professional affiliations) for appointed committee
members should be made widely available to the public
(e.g., via a website). Such information should clearly
illustrate an individual's qualifications for serving on the
committee.
c.	The selection of members to serve on a scientific or
technical FAC should be based on expertise, knowledge,
contribution to the relevant subject area, balance of the
scientific or technical points of view represented by the
members, and the consideration of conflicts of interest.
Peer-reviewed committees convened solely for the purpose of reviewing
research proposals to provide individual input on intra- or extramural funding
decisions are not covered by this policy. GSA has provided additional guidance
[24-27],
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Members of scientific and technical FACs should be
appointed as special government employees. The Agency is
to make all Conflict of Interest Waivers granted to
committee members publicly available (e.g., via a website),
d. All reports, recommendations, and products developed by
FACs are to be treated as solely the findings of such
committees rather than of the EPA, and thus are not subject
to Agency revision.
At the EPA, FACs are overseen by the Office of Federal Advisory
Committee Management and Outreach [OFACMO] with legal
support from the Office of General Counsel (OGC). All EPA FACs
are expected to comply with the requirements of the Federal
Advisory Committee Act (5 USC Appendix 2) [21] and the
regulations issued by the General Services Administration (41
CFR Part 102-3) [22].
The Agency adheres to the current standards governing conflict
of interest as defined in statutes and implementing regulations.
The Office of General Counsel's Ethics Office develops standard
procedures and ethics training for Special Government
Employees (SGEs) who serve on scientific FACs. These
procedures include the submission and review of Confidential
Financial Disclosure Forms for SGEs serving on advisory
committees, EPA Ethics Advisory 08-02: "Ethics Obligations
for Special Government Employees" [28], and completion of an
online and/or in-person Office of Government Ethics course.
Some FACs at the EPA are staffed with representative members.
These committee members represent the point of view of a
group or organization and are not subject to the conflict of
interest requirements referenced above.
For technical documents designated as Influential Scientific
Information (ISI) or Highly Influential Scientific Assessment
(HISA) where independent peer reviews will be conducted
by an independent contractor under contract with EPA, the
contractor and the EPA contracting officer will adhere to the
Conflict of Interest Review Process for Contractor-Managed
Peer Reviews.13
D. Professional Development of Government Scientists
Scientific leadership is a key component of advancing the
mission of the EPA. Agency scientists are therefore encouraged
to engage with their peers in academia, industry, government,
A description of the process can be found at: https://www.epa.gov/osa/
conflicts-interest-review-process-contractor-managed-peer-reviews-epa-nigh-
ly-influential
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and non-governmental organizations, consistent with their
work responsibilities. Examples of encouraged professional
activities include presenting their work at scientific meetings,
serving on editorial boards and on scientific expert review
panels, and actively participating in professional societies
and national/international scientific advisory and science
assessment bodies. It is Agency policy to:
a.	Encourage publication and presentation of research findings
in peer-reviewed, professional, or scholarly journals and at
professional meetings.
b.	Allow Agency scientists to become editors or editorial board
members of peer-reviewed, professional, or scholarly
journals.
c.	Allow participation in professional societies, committees,
task forces and other specialized bodies of professional
societies, including serving as officers or on the governing
boards of such societies.
d.	Encourage Agency scientists to obtain training to keep
current their scientific qualifications and professional
certifications.
e.	Allow Agency scientists to accrue professional awards,
honors and patents for their research and discoveries.
V. The EPA's Scientific Integrity Committee
The Agency's Scientific Integrity Committee is charged with
implementing, reviewing, and revising as needed policy
governing the four specific areas of scientific integrity
described in the previous section. The committee is chaired by
the Scientific Integrity Official and consists of Deputy Scientific
Integrity Officials that represent each of the Agency's Program
Offices and Regions.14
A. Roles and Responsibilities of the Scientific Integrity
Committee
•	Provide leadership for the Agency on scientific integrity.
•	Implement this policy across the Agency in a consistent
manner.
•	Promote Agency compliance with this policy, including
safeguarding against and mechanisms to ensure
accountability for any alteration or manipulation of scientific
data by managers and other Agency leadership.15
14	The Scientific Integrity Committee Charter can be found at: https://www.
epa.gov/osa/basic-information-about-scientific-integrity
15	A description of the procedures can be found at: https://www.epa.gov/osa/
allegation-procedures-for-scientific-integrity-violations
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•	Address Scientific Integrity Policy concerns, updates, and
amendments.
•	Provide an annual meeting and report on scientific integrity
implementation and scientific misconduct issues within the
Agency.
•	Keep the Agency's Senior Leadership informed on and
involved with the Agency-wide status of scientific integrity, as
necessary and appropriate. The EPA Scientific Integrity
Committee will develop Agency-wide best practices for the
approval of scientific products and communications. Each
Program Office and Regional Office will use these to develop
and document consistent, transparent, and predictable
procedures for clearance, consistent with the Scientific
Integrity Committee's best practices. The procedures will
include guidance for clearance elements, time frames for
clearance, and a process for redress if clearance procedures
are not met.
•	Develop a framework for Agency clearance procedures for
scientific products as a guidance for Program Offices and
Regional Offices.
•	Evaluate Program Offices' and Regional Offices' clearance
procedures for scientific products and make
recommendations as appropriate to promote standardization
across the Agency.
B. Scientific Misconduct
The Scientific Integrity Official or his/her designee shall
coordinate with the Office of the Inspector General (OIG) on
issues of scientific misconduct. The Agency already has in
place clearly articulated policies protecting against scientific
misconduct by all Agency employees, including managers
and other Agency leadership, in the following two important
documents:
•	Scientific Misconduct in the EPA Conduct and Discipline
Manual (Appendix - Guidance on Corrective Discipline,
Tables of Offenses and Penalties #45 - Scientific Misconduct)
includes discipline guidelines for fabrication, plagiarism,
misrepresentation, and causing a subordinate to engage in
scientific misconduct [30],
•	Policy and Procedures for Addressing Research Misconduct
provides policy on reporting, procedures, investigations, and
adjudication of research misconduct by the EPA's employees,
contractors, and recipients of assistance agreements [31].
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C.	Training
As part of its mandate, the Scientific Integrity Committee
oversees the development and implementation of training
related to scientific integrity for all Agency employees.
Contractors, cooperators, grantees, and volunteers are also
encouraged to take this training and may be required to do so
if such training is part of their respective agreements with the
EPA.
In addition, accredited EPA laboratories provide annual
Laboratory Ethics and Data Integrity Training for scientists
engaged in generating scientific data to support cleanups,
enforcement, and environmental assessments. This annual
scientific ethics training fulfills accreditation standards and
reinforces an understanding of the laboratory ethics policy.
D.	Annual Reporting
The Scientific Integrity Official, with input from the Deputy
Scientific Integrity Officials, is responsible for generating
and making publicly available an annual report to the EPA
Science Advisor on the status of scientific integrity within the
Agency. The report is expected to highlight scientific integrity
successes throughout the Program Offices and Regions, as
well as identify areas for improvement and develop a plan for
addressing critical weaknesses, if any. As part of this annual
review, Deputy Scientific Integrity Officials are responsible for
certifying compliance with the Agency Scientific Integrity Policy
and report on scientific integrity implementation and scientific
misconduct issues within their respective Offices or Regions.
The Agency will utilize its FMFIA Management Integrity
Program to collect these certifications. In advance of completing
the annual report, the Scientific Integrity Committee will
conduct an Agency-wide annual meeting on scientific integrity
that will include the involvement of senior EPA leadership,
reports from offices and programs, and an opportunity for
input from the EPA scientific community.
The report should include, but is not limited to, the findings of
scientific integrity violations. The report should also include
lessons learned during the previous year, input from the annual
meeting, and recommendations for action/deliberation by the
Scientific Integrity Committee during the upcoming fiscal year,
to ensure continuous improvement in implementation of the
Scientific Integrity Policy.16
The Scientific Integrity Program's Annual Reports can be found at https://
www.epa.gov/osa/basic-informati on-about-scienti fic-integrity#Sci entificlnteg-
rityAnnualRep orts
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E. Amending the Scientific Integrity Policy
This policy will become effective upon approval.
At a minimum, this policy is to be reviewed every two years by
the Scientific Integrity Committee to ensure its effectiveness
and adherence with applicable rules and regulations.
This policy shall be revised as recommended by the Scientific
Integrity Committee and approved by the EPA Science Advisor.
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Bibliography
[1]	Ruckelshaus, William (1983) Fishbowl Memo.
https: / / archive.epa.gov/ epa/aboutepa/ruckelshaus-takes-
steps-improve-flow-agency-information-fishbowl-policy.
html
[2]	Executive Office of the President, Office of Management and
Budget (2002) Information Quality Guidelines, https://
obamawhitehouse.archives.gov/ sites / default/ files / omb /
assets/omb/inforeg/iqg_oct2 002.pdf
[3]	Executive Office of the President, Office of Management
and Budget (2005) OMB Information Quality Bulletin for
Peer Review. https://www.gpo.gov/fdsys/granule/FR-
2005-01-14/05-769
[4]	U.S. Environmental Protection Agency (2008) EPA Quality
Policy, https://www.epa.gov/sites/production/files/2015
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Handbook, Third Edition, https://www.epa.gov/sites/
production/files/2 016-0 3/documents / epa_peer_review_
handbook_4th_edition.pdf
[6]	U.S. Environmental Protection Agency (2002) Guidelines for
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quality-guidelines.pdf
[7]	U.S. Government Printing Office (1997) 5 CFR 2635.702
http://www.gpo.gov/fdsys/pkg/CFR-1997-title5-vol3/pdf/
CFR-1997-title5-vol3-sec2635-702.pdf
[8]	U.S. Environmental Protection Agency (1999) Principles of
Scientific Integrity, https://www.epa.gov/sites/production
/ files/2014-11/documents / epa-principles-of-scientific-
integrity.pdf
[9]	U.S. Environmental Protection Agency (2011) Action
Development Process Library.
https://yosemite.epa.gov/sab/sabproduct.
nsf/5088B3878A90053E8525788E005EC8D8/$File/
adp03-00-ll.pdf
[10]	U.S. Environmental Protection Agency, Science Policy
Council (1995) Guidance for Risk Characterization, https://
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www.epa.gov/sites/production/files/2015-ll/
documents/guidance-risk-characterization-febl995.pdf
[11]	U.S. Environmental Protection Agency Science Policy
Council (2000) Risk Characterization Handbook, https://
www.epa.gov/ sites/production/files/2 015 -10/documents /
osp_risk_characterization_handbook_2000.pdf
[12]	U.S. Environmental Protection Agency (2011) Policy to
Assure Competency of Laboratories, Field Sampling, and
Other Organizations Generating Environmental
Measurement Data under Agency-Funded Acquisitions, and
(2004) Assuring the Competency of Environmental
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gov/sites/production/files/2015-03/documents/fem-lab-
competency-policy.pdf
[13]	U.S. Environmental Protection Agency (2000) Employee
Rights under the Whistleblower Protection Act. https://
www.epa.gov/office-inspector-general/epa-oig-hotline
For employees only: http://intranet.epa.gov/ohr/rmpolicy/
ads/orders/lOOO.pdf
[14]	U.S. Environmental Protection Agency (2002) The Ethics
Program, https: //www.epa.gov/ aboutepa/ about-office-
general-counsel-ogc
For employees only: http://intranet.epa.gov/ogc/ethics.htm
[15]	U.S. Environmental Protection Agency (2009) National
Approach to Response Crisis Communications Plan, https://
response.epa.gov/site/site_p rofile.aspx?site_id=5083
[16]	U.S. Environmental Protection Agency (2006) Peer Review
and Peer Involvement at the U.S. Environmental Protection
Agency, https://www.epa.gov/sites/production/files/
2015-01/documents/peer_review_policy_and_memo.pdf
[17]	Removed by errata sheet- document was never finalized
[18]	U.S. Environmental Protection Agency (2004) Peer Review
Agenda, http:/ / cfpub.epa.gov/ si/si_public_pr_agenda.cfm
[19]	Removed by supplemental information sheet- now
reference [32]
[20]	U.S. Environmental Protection Agency (2003) A Summary
of General Assessment Factors for Evaluating the Quality of
Scientific and Technical Information, https://www.epa.gov/
sites/production/files/2015-01/documents/assess2.pdf
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[21]	Title 5 United States Code, Appendix 2 (1972) https://
www.gpo.gov/fdsys/pkg/USCODE-2010-title5/html/US
CODE-2010-title5-app-federalad.htm
[22]	41 Code of Federal Regulations, Part 102-3 (2006) Federal
Advisory Committee Management, http://www.ecfr.gov/cgi
-bin/text-idx?SID=9835778e2d49a4bc797d9ac5859eb050
&mc=true&node=pt41.3.102_63&rgn=div5
[23]	The White House, Office of the Press Secretary (2010)
Presidential Memorandum - Lobbyists on Agency Boards
and Commissions, https://obamawhitehouse.archives.gov/
the-press-office/presidential-memorandum-lobbyists-
agency-boards-and-commissions
[24]	GSA Guidance (1998) Appointment of Consultants to FACA.
http://www.gsa.gov/portal/content/100786
[25]	GSA Guidance (2011) Appointment of Special Government
Employees, http: / / www.gsa.gov/ portal/content/10079 6
[26]	GSA Guidance (2000) Public Access to Records (FACA).
http://www.gsa.gov/portal/content/100785
[27]	GSA Guidance (2011) When FACA is and is Not Applicable
to Interactions with the Private Sector, http://www.gsa.gov/
portal/content/100794
[28]	U.S. Environmental Protection Agency (2008) Ethics
Obligations for Special Government Employees, https://
www.epa.gov/sites/production/files/2015-02/documents/
ethicsadvisory.pdf
[29]	Removed by errata sheet- draft was never finalized
[30]	U.S. Environmental Protection Agency, Office of Human
Resources (1985) Appendix - Guide on Corrective
Discipline. For employees only: http://intranet.epa.gov/
ohr / rmpolicy/ads / cadm/html / app.htm
[31]	U.S. Environmental Protection Agency (2003) Policy
and Procedures for Addressing Research Misconduct.
https://www.epa.gov/sites/production/files/2014-04/
documents/epapolicy.pdf
[32]	U.S. Environmental Protection Agency (2015) Peer Review
Handbook, Fourth Edition, p. 79. https://www.epa.gov/
sites/production/files/2016-03/documents/epa_peer_
review_handbook_4th_edition.pdf
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http://intranet.ord.epa.gov/scientific-integrity
For additional information or to report an allegation:
Scientific Integrity Official
Francesca T. Grifo, PhD
Grifo.francesca@epa.gov
(202) 564-1687
To report fraud, waste or abuse,
contact theOIG hotline (Office of Inspector General):
E-mail: OIG_Hotline@epa.gov	Write:
Phone: 1-888-546-8740	EPA Inspector General Hotline
Fax: 202-566-2599	1200 Pennsylvania Avenue NW
Online: http://www.epa.gov/oig/	Mailcode 2431T
hotline.htm	Washington, DC 20460
Publication Number: 601B17001

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