Office of Inspector General

U.S. Environmental Protection Agency

At a Glance

23-E-0013
March 7, 2023

Why We Did This Evaluation

The U.S. Environmental
Protection Agency Office of
Inspector General conducted this
evaluation to determine whether
the EPA followed applicable
policies and procedures to
develop and publish the
January 19, 2021
perfluorobutane sulfonic acid
toxicity assessment. Two weeks
after publication, the EPA
removed the toxicity assessment
from its website, citing political
interference and Scientific
Integrity Policy Violations. The
EPA republished the toxicity
assessment in April 2021.

The EPA's Scientific Integrity
Policy, established in 2012,
states that science is the
backbone of the EPA's
decision-making and that the
Agency depends on the integrity
of its science to protect human
health and the environment. All
EPA employees—including
scientists, managers, and
political appointees—must follow
the Scientific Integrity Policy.

This evaluation supports an EPA
mission-related effort:

•	Operating efficiently and
effectively.

This evaluation addresses a top
EPA management challenge:

•	Safeguarding scientific integrity.

Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.

List of OIG reports.

The EPA's January 2021 PFBS Toxicity Assessment
Did Not Uphold the Agency's Commitments to
Scientific Integrity and Information Quality

What We Found

The EPA's actions left the
public vulnerable to
potential negative impacts
on human health.

The EPA did not follow the typical intra-agency
review and clearance process during the
development and publication of the January 2021
perfluorobutane sulfonic acid, or PFBS, toxicity
assessment. During final clearance, a political

appointee directed that a last-minute review be conducted of the uncertainty
factors used to calculate toxicity values, resulting in a scientific disagreement
that caused delay, confusion, and significant changes to the near-final, peer-
reviewed work product. These changes included replacing single toxicity values
with unprecedented toxicity ranges. Users of the PFBS toxicity assessment—
for example, regulated entities cleaning up PFBS contamination—could have
selected a less stringent value within this range, which may have been less
costly but also less protective of human health. While EPA staff expressed
scientific integrity concerns about the last-minute review and risks to public
health, the EPA lacked policies and procedures to address these concerns.
Without updates to policies and procedures, the Agency cannot fulfill its
commitment to scientific integrity and information quality.

Recommendations and Planned Agency Corrective Actions

We make a total of five recommendations in this report:

•	Three to the assistant administrator for Research and Development to
reduce procedural confusion and strengthen existing policies, procedures,
and guidance by clarifying if and when comments expressing scientific
disagreement can be expressed; making clear if and when toxicity ranges
are acceptable; and using the OIG as a resource for high-profile scientific
integrity concerns that relate to political interference or that assert risk to
human health or the environment.

•	One to the assistant administrator for Mission Support to update policies
and procedures on environmental information quality to require additional
quality assurance reviews for EPA products.

•	One to the deputy administrator to strengthen the EPA's culture of scientific
integrity, transparency, and accountability of political leadership actions
when changes occur as a result of policy decisions.

The EPA disagreed with all five recommendations, which remain unresolved.

Noteworthy Achievement

In fiscal year 2022, the Scientific Integrity Program and the OIG increased the
frequency of their meetings from quarterly to every two weeks to facilitate timely
communication of scientific integrity issues and discuss appropriate action.

-------