Best Practices for Designating Authorship
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Best Practices
for
Designating Authorship
Scientific
US Environmental Protection Agency
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The U.S. Environmental Protection Agency is charged by Congress with
protecting the Nation's land, air, and water resources. Under a mandate of
national environmental laws, the Agency strives to formulate and implement
actions leading to a compatible balance between human activities and the
ability of natural systems to support and nurture life.To meet this mandate,
EPA programs provide data and technical support for solving environmental
problems today and building a science knowledge base necessary to manage
our ecological resources wisely, understand how pollutants affect our health,
and prevent or reduce environmental risks in the future.
EPA's Scientific Integrity Official (ScIO) champions scientific integrity
throughout the Agency.The ScIO chairs the Scientific Integrity Committee
comprised of Deputy Scientific Integrity Officials who represent each EPA
program office and region. Science is the backbone of EPA's decision-making.
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 full text of this document is available on EPA's website at:
https://www.epa.aov/osa/authorship-best-practices
Cover Design by Armando Chagolla, October2014, & Emily Brantner, July 2016.
EPA Publication number 601K16001
Printed on 100% Postconsumer, Process Chlorine Free Recycled Paper
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Contributors &
AcKnowledgments
Contributors
FrancescaT. Grifo
Francesca is the Scientific Integrity Official at the U.S. Environmental
Protection Agency. Previously she was the Director of the Scientific Integrity
Program at the Union of Concerned Scientists. In addition she has 20 years
of experience in biodiversity conservation at United States Agency for
International Development, Biodiversity Support Program, National Institutes
of Health, the American Museum of Natural History, and Columbia University.
She holds a BA in biology from Smith College and a Ph.D. in plant systematics
from Cornell University.
Gary S. Russo
Gary is an Environmental Scientist in the Office ofWater. Before arriving
at EPA, he was an academic biomedical research scientist. He holds a
B.A. in biology from the University of California San Diego and a Ph.D. in
neuroscience from Yale University.
Martha Otto
Martha is the Scientific Integrity Program lead in the Office of the Science
Advisor. Martha has over 25 years of experience in hazardous waste site
remediation, innovative treatment technologies, and policy, regulation, and
guidance development. She holds a BS in biology and an MS in environmental
science and engineering from VirginiaTech.
Acknowledgments
The contributors wish to acknowledge:
The Scientific Integrity Committee for their role in championing Scientific
Integrity throughout the Agency and their helpful review and comments.
Armando Valentino Chagolla, for his layout and overall design templates for
this report.
Amanda Redfern and Emily Brantner for their assistance in formatting the
boxes and text and adapting the design templates for this content.
Melinda Gormley andTom Sinks for helpful review and comments.
Taylor Cox for photo research.
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Table of
Contents
Contributors and Acknowledgments
Boxes
Executive Summary
1. Introduction
2. Authorship Criteria
3. Authorship Order
4. Authorship Approval & Dispute Resolution
5. Author Roles
6. Shared Authorship
7. Contribution Statements & Authorship Agreements
Contribution Statements
Authorship Agreements
8. Authorship Responsibilities
9.Trainees,Technicians, and Contractors
Trainees
Technicians
Contractors
10. Common Authorship Abuses
11. Plagiarism and Self-Plagiarism
Text Recycling
Redundant Publication
12. Conflict of Interest and Loss of Impartiality
Conflict of Interest
Loss of Impartiality
13. Bias
14. Copyright Issues
Appendix 1
Appendix 2
End Notes
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Boxes v
boxes
Box 1.Yours, Mine, and Ours 3
Box 2. Can We Renegotiate? 5
Box 3.Too Little,Too Late 9
Box 4. Assuming Authorship 13
Box 5. Spousal Privilege 15
Box 6. All in the Family 15
Box 7. Repeat Review 17
Box 8.Taking Stock 19
Box 9. Diverse Points ofView 21
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CO
tive
ummary
U.S. EPA is committed to transparency in its interactions with the public.The
designation of authorship plays a critical role in transparency by identifying
who is responsible for the information and conclusions in EPA work products
and how the work products were developed. Identification of the contributors
to EPA work products helps to establish public confidence in the scientific
integrity of those products. Such recognition can also be an essential measure
of job performance and necessary for career advancement. However, the issue
of who qualifies as an author can sometimes be contentious.The purpose of
the U.S. EPA Authorship Best Practices document is to provide a common
understanding across the Agency for attributing credit and accountability
to individuals and groups who contribute to those EPA work products that
designate authorship.
EPA's Scientific Integrity Policy affirms the responsibility of every EPA
employee to appropriately characterize, convey, and acknowledge the
intellectual contributions of others. An individual who knowingly publishes
the intellectual work of another without appropriate credit has committed
plagiarism.
Any, all, and only those contributors fulfilling al
should be named as an author:
of the following three criteria
1. Made a substantial intellectual contribution.
2. Wrote or provided editorial revisions with critical intellectual content.
3. Approved the final version and agreed to be accountable for all
aspects of the work.
Authorship also conveys responsibility. Authors must represent their work
fairly and accurately, avoid conflicts of interest, and ensure impartiality. All
authors are responsible for the overall accuracy and quality of the work product,
and may be liable for research misconduct associated with its content.
Many authorship disputes arise because project participants have not
discussed authorship or have done so late in the project. Contribution
statements and authorship agreements can be useful tools that facilitate
these discussions and minimize authorship disputes and authorship abuse.
The most important best practice to avoid authorship disputes is to discuss
project responsibilities and authorship among participating individuals before
a project commences and periodically as work progresses. Most authorship
disputes can be avoided or resolved by engaging in open and straightforward
conversations early and often.This document is intended to provide a set of
objective criteria and general standards that can be used to prevent or resolve
authorship issues and ensure the appropriate acknowledgment of individual
contributions in EPA work products.
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2
1. In
CO
EPA's Scientific Integrity Policy encourages the publication and presentation
of research findings and the communication of scientific information to the
public1. EPA's Principles of Scientific Integrity require that EPA employees
represent and acknowledge the intellectual contributions of others in published
work such as journal articles and technical reports and refrain from taking
credit for work with which they were not materially involved2. One way that EPA
employees receive recognition for their individual contributions to such works
is through the designation of authorship.The assignment of authorship on work
products, however, can sometimes become contentious. Authorship practices
are often guided by the traditions and customs of scientific disciplines,
institutions, research groups, and the standards and policies of journals or
publishers.This can lead to ambiguity, uncertainty, and inconsistency in how
authorship is assigned to EPA work products3.This document fulfills the
need for a common understanding of the best practices for recognizing the
contributions of individuals through authorship of EPA work products.
EPA's Scientific Integrity Policy also affirms the Agency's commitment to
transparency in its interactions with the public.The designation of authorship
plays a critical role in transparency by identifying who is responsible for
the information and conclusions in EPA work products and how they were
developed. "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."4
The best practices described in this document apply prospectively to any EPA
work product where authorship is designated, including but not limited to
journal articles, reports, presentations, posters, documentation of models or
software, communication products, technical support documents, and guidance
documents.These best practices also address situations involving non-EPA
employees such as students, fellows, interns, technicians, and contractors, and
address issues related to conflicts of interest, bias, plagiarism, and copyright.
This document does not create new rules for designating authorship.The best
practices described in this document represent widely accepted approaches
derived from the policies written by centers and laboratories of EPA's Office
of Research and Development including the National Center for Environmental
Assessment, National Exposure Research Laboratory, National Health and
Environmental Effects Research Laboratory (NHEERL), and National Risk
Management Research Laboratory.These best practices also considered the
authorship policies of the Nature journals5, American Chemical Society6, the
Council of Science Editors7, the Authorship Policy of the Centers for Disease
Control8, the International Committee of Medical Journal Editors (ICMJE)9, a
review on scientific authorship practices published by Larry Claxton (retired
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from EPA's NHEERL)10, and resources from the
Office of Research Integrity in the Department of
Health and Human Services11.
3
It is unreasonable to expect a single document to
settle every potential authorship issue. Instead,
this document is intended to provide a set of
objective criteria and general standards that can
be used to prevent or resolve authorship issues
and ensure the appropriate acknowledgment of
individual contributions in EPA work products.
Authors publishing outside of their EPA
duties should consult with the appropriate
ethics officials and also refer to the individual
publication's policies and instructions to authors.
While the Office of General Counsel attorneys
may be consulted on intellectual property issues
that arise in connection with EPA work products,
they do not provide advice to employees engaged
in outside writing or publication.
Although this document identifies a variety
of best practices related to authorship, the
most important best practice is to discuss
responsibilities and authorship among
participating individuals before a project
commences and periodically as work progresses.
Most authorship disputes can be avoided
or resolved by engaging in open and frank
conversations early and often. EPA defines a
Quality Management Plan as an organization's
quality-related policies and procedures, criteria
for application, areas of application, and roles,
responsibilities, and authorities. It might be
useful to think of this document as a type of
Quality Management Plan for determining
authorship of EPA work products.
Box 1: Yours,Mine,
ana Ours
Example: You are assigned the task of
completing a work product that was started
by another EPA employee a few years ago.
The other employee had already designed
an approach, researched and compiled
information, and developed a rough draft,
but was reassigned to more urgent projects
and never completed the work product. All
you need to do is revise the existing draft.
However, you soon realize the draft needs
more than revision, and you essentially re-
write the entire document. You remove the
other employee's name from the author list
because you completely reorganized the
document, the other employee apparently
doesn't care about authorship because he
never finished the project, and after all, we
are "one EPA." Is this consistent with EPA's
Authorship Best Practices?
Answer: No.The previous employee made
a substantial intellectual contribution
(criterion #1), wrote critical intellectual
content (criterion #2), and may be willing to
help you finalize the work product if given
an opportunity (criterion #3). Substantially
revising someone else's work does not
discount the significance of the original
contribution. You should at least contact
the previous employee to discuss and find
consensus on the issue of authorship for the
final work product.
"The most important best practice is to discuss
responsibilities and authorship among participating
individuals before a project commences and
periodically as work progresses. "
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4
CO
rship
eria
The term "author" applies to any individual who makes a substantial
contribution, as defined below, to an EPA work product. Authorship refers to
the listing of contributors to the work product.
To qualify as an author, an individual must make a substantial contribution to
the work product that fulfills all of following three criteria:
1. Made a substantial intellectual contribution to the work product. An
individual may make a substantial intellectual contribution in several
different ways, including:
a. Conception and design (e.g., formulation of hypotheses,
refining research ideas, development of study objectives; or the
definition of experimental, statistical, modeling, or analytical
approaches), or
b. Acquisition of data or development of models (e.g., non-
routine fieldwork, such as adapting or developing new
techniques or equipment necessary to collect essential
data; non-routine lab work such as development of new
methods or significant modification to existing methods
essential to the research; literature searches;
theoretical calculations; and development and
application of modeling specific to the project), or
c. Analysis and interpretation of data.
2. Wrote or provided editorial revisions to the work product
containing critical intellectual content12.
3. Approved the final version to be published and agreed to be
accountable for all aspects of the work product.
Any individual who has met these three criteria, independent of their rank,
status, or affiliation, should be named as an author. Any individual who has
not met these three criteria, independent of their rank, status, or affiliation,
should not be named as an author. An individual who knowingly publishes the
intellectual work of another without giving appropriate credit has committed
plagiarism. Suppressing authorship by unreasonably interfering in the ability
of an individual to meet these three criteria is a violation of EPA's Scientific
Integrity Policy and should be reported to EPA's Scientific Integrity Official.
Individuals who make a substantial contribution to a work product but do
not meet the authorship criteria specified above should be listed in an
acknowledgments section in the work product with a brief description of their
role, if possible. Many journals allow and even encourage acknowledgment of
contributions that do not merit authorship.The ICMJE guidelines recommend
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that contributors who do not meet all authorship
criteria should not be listed as authors, but
they should be acknowledged. Contributions
worthy of acknowledgment can include literature
searching, contract or project management,
supervision, mentorship, statistical consultation,
manuscript review, advice, provision of materials
or space, routine assistance, financial support,
and grammatical or stylistic editing. Individuals
listed in the acknowledgments section should
be notified before final publication of the
work product. Some journals (mainly in the
United States) require the signature of those
acknowledged.
Decisions about removing the name of a
previously listed author or withdrawing a
work product after it is submitted for public
dissemination should be carefully considered. An
individual acknowledged or listed as an author
may remove their own name from a work product
or voluntarily withdraw their work product if they
are the sole author, but an author should not be
compelled to remove their name or withdraw their
work product unless doing so is necessary to
comply with EPA's Authorship Best Practices or
EPA's Scientific Integrity Policy.
5
Box 2: CarxWe
Renegotiate?
Example: You are one of several team
members about to begin a project. All of the
team members agree on authorship order,
with the project leader as primary author.
Just as the project begins, the project leader
is promoted to branch chief.The new branch
chief can no longer lead the day-to-day
operation of the project, so she assigns one
of the team members as the new project
leader. Expecting to assume the role of
primary author, the new project ieader begins
discussing a new authorship order. However,
the branch chief says the existing authorship
order will remain because it has already been
debated and settled. Is this consistent with
EPA's Authorship Best Practices?
Answer: It depends. Authorship order does
not need to change simply because the status
of an author has changed. However, a change
in authorship order may be appropriate if
an author's responsibilities change. With a
promotion to a more "senior" position and
reduced day-to-day project responsibilities,
the new branch chief may want to suggest
taking the role of "senior" author and be listed
last, and the new project ieader taking the role
(and responsibilities) of primary author and be
listed first.
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3. Authorship
Urcer
The order authors are listed in a work product can matter greatly, especially
for authors who are establishing their careers. However, authorship order can
mean different things in different settings. In many scientific disciplines, the
position of first author is highly valued because it indicates the primary author
who did most of the work and who takes responsibility for the entire work
product (see Section 5 for more information about the role of primary author).
Because of the way literature is often cited (e.g., "First Author, et al.,Year"),
the first author's name is often the most visible to readers. When establishing
authorship order becomes unmanageable (e.g. when a work product has a
large number of authors), authors may be listed in alphabetical order. Because
readers may not be able to accurately infer the significance of authorship order,
authors may explain the order of authorship and the nature of the contributions
of each author in a footnote or acknowledgment (see Section 7 for more
information about contribution statements).
"Most authorship disputes can be avoided
or resolved with open and trank discussions
about responsibilities and contributions"
A work product with a list of authors typically lists the primary author first,
followed by co-authors in descending order of their contribution. Exceptions
to this general rule occur when authorship order is determined alphabetically,
and in some disciplines where it is customary to list a "senior" author last even
though the senior author's level of contribution qualifies the senior author to be
listed earlier in the author list (see Section 5 for more information about senior
authors). In cases where two or more authors contribute equally to a work
product, equal contributorship may be indicated by a footnote or a caption such
as, "These authors contributed equally to this work."
Authorship order generally reflects the relative contributions of each author.
However, other factors can potentially affect authorship order. Depending
on the scope of a particular project, a project could result in several work
products, each involving different authors and/or different authorship orders.
Changes to authorship order may be necessary if the actual contributions of
authors differs significantly from those originally expected, such as when an
author accepts increased responsibility or delegates a portion of his or her
responsibility to other authors. In such circumstances, the order of authors
should reflect the actual contributions of each author (see Section 4 for
information about authorship approval and dispute resolution). Again, the best
practice is early and frequent conversations about authorship, including author
order.
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4. Authorship Approva
& Dispute F solution
7
Authorship and authorship order should be a collective decision by all
project contributors under the leadership of the primary author. In general,
project contributors should strive for a consensus decision on authorship and
authorship order. If a consensus cannot be reached among contributors, the
issue(s) should be raised to the primary author's immediate supervisor as the
first recourse.The supervisor in the primary author's chain of command who
does not have a conflict of interest should facilitate resolution of the issue.
Attempts should be made to resolve outstanding issues at the lowest level
of authority. Any resolution to an authorship dispute must be consistent with
EPA's Scientific Integrity Policy. If attempts to resolve the issue(s) fail, the
project contributor may contact EPA's Scientific Integrity Official. Authorship
disputes should be resolved before the work product is submitted for EPA
clearance.
Most authorship disputes can be avoided or resolved with open and
frank discussions about responsibilities and contributions among project
participants before a project commences and periodically as work progresses.
One important best practice is for collaborators to begin the project by
anticipating, discussing, and resolving potential areas of disagreement and
define a process for constructively handling disputes should they arise.
Discussion of authorship and authorship order will optimally begin at the
inception of a research project and involve a purposeful and thoughtful
examination of expected contributions of the individuals involved in the
project13.These discussions should be initiated and led by the primary author
of the work product. Key points of agreement should include the expected
contributions of each participant, how credit will be attributed to each
collaborator's institution, how and by whom public presentations will be made,
and when and how to handle intellectual property and patent applications.
Many of these issues can be addressed through simple discussions. In
some circumstances, authors might want to seek the mediation of a neutral
third party with no direct involvement in the project to help facilitate such
discussions and maximize their effectiveness.
As discussed previously, a single project may result in more than one work
product with different authors and/or different authorship orders. In such
circumstances, it is especially important to discuss authorship as soon
as possible. It is helpful for all contributors to recognize that authorship
and authorship order could change during a project to better reflect the
actual contributions of the contributors. Such changes, however, should be
a consensus decision after considering each individual's perspective and
reviewing each individual's contributions. Such discussions should be open,
honest, and conducted in a professional manner.
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5. Author
Ko es
At least one author, usually the primary author, should take responsibility
for the integrity of the work product as a whole from inception to publication.
It is the responsibility of the primary author to manage and coordinate the
development and dissemination of the work product, including drafting,
reviewing, revising, clearing, and publishing.The primary author is the author
who typically has the greatest understanding of the goals, approaches and
findings of the project, the contributions of all participants in the project, and
the common practices of the scientific discipline and target audience.
Although the primary author has the greatest responsibility for developing
the work product, every individual author should read and approve (preferably
in writing) the work product that is submitted to EPA's clearance process and
any subsequent versions that are publicly disseminated. Although individual
authors may be responsible for developing specific sections of a work product,
each individual author should understand and be able to conceptually explain,
defend, and endorse the work product as a whole. It is the responsibility of the
primary author to ensure that all authors agree to take responsibility for the
work product and the validity of its content.
As described in Section 3, some disciplines identify a senior author by listing
their name last in the list of authors. A senior author is usually a senior member
of the project team who served as the driving force behind the concept,
organized the project, and provided guidance throughout execution of the
project. A senior author may be the head of a research group, laboratory,
or department under which the project was conducted, and/or the mentor
or advisor to students or more junior scientists with a more direct role in
executing the project.
The position of last author can be highly valued because it often indicates
the senior author with the highest level of academic and/or supervisory
status among the listed authors. Because of the prestige associated with the
designation of senior author, a senior author may be listed last even though he/
she had a more significant role in the work product than authors who precede
him/her in the author list. Nevertheless, the senior author must fulfill all of the
criteria of authorship specified in Section 2.
The corresponding author is responsible for submitting a work product to
a journal or other medium for publication, and for communicating with the
publisher on issues of publication revision and acceptance.The name and
email address of the corresponding author is often noted in the work product,
as he or she serves as a point of contact. After publication, the corresponding
author manages all communication and correspondence associated with the
work product on behalf of the other authors.
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6. Shared
Authorship
The rising trend in trans-disciplinary research
calls for a process to convey shared authorship.
If two or more authors contribute equally to a
work product, the convention is to list the authors
alphabetically with a footnote designating equal
contributorship and noting why the order was
selected. In such circumstances, all authors are
equally responsible for the quality of the work
product.
Group authorship may be appropriate for
work products developed by a large number of
individuals14. If each individual in a group has
contributed equally, the group name should be
listed as the author, with individual author names
appearing in a footnote, byline, or elsewhere in
the work product for proper indexing of individual
authors in publication databases. If only a
subgroup of individuals in a group meets the
authorship criteria specified in Section 2, the
group name should be listed as the author and
only the individuals who meet the authorship
criteria should be identified as members
of the group. Group members who made a
contribution to the project but do not meet the
authorship criteria should be identified in the
acknowledgments.
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Box 3: Too-Little,
Too Late
Example: A colleague in an earlier stage
in his career submitted a review article to
a journal that was rejected. Your colleague
contacts you and asks if you would co-
author the article with him because he
believes that adding you as an author
would increase the chance of acceptance.
You have collaborated and published
articles together in the past, and you have
many years of experience on the subject.
You read the manuscript and think that it is
fairly good. You accept the offer because
you want to help your younger colleague,
you believe that you are qualified to be an
author (you could have written the review
yourself), and you get another publication
on your CV. Is this consistent with EPA's
Authorship Best Practices?
Answer: No. Authorship is only
appropriate when an individual makes
a substantial contribution to the work
product that fulfills all three criteria
specified in Section 2. Helping to
reorganize the review to address the
editor's previous criticisms, reviewing
revisions to help ensure that the review
is clear and accurately represents
the current science, and accepting
responsibility for the integrity of the review
may be all that is needed to qualify as an
author, and will likely be more helpful to
your younger colleague as well.
"At least one author, usually the primary author,
should take responsibility for the integrity of the work
product as a whole from inception to publication."
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7. Contribution Statements
& Authorship Agreements
Contribution Statements
A contribution statement can be a useful tool to affirm each author's role in a
work product. A contribution statement describes each author's contributions
and helps to discern the value of those contributions to the work product,
from inception to publication. For example, a contribution statement might
describe who developed the idea for the work product, who obtained funding,
who performed and/or coordinated data collection, who analyzed the data,
who interpreted the data, and who was primarily responsible for writing and/
or revising the manuscript. A clear and concise contribution statement helps
to ensure that all authors are properly recognized for their work on a project,
especially on a large project that has many authors, is multi-disciplinary, and/
or is performed at different locations or institutions. A contribution statement
can also help readers identify the appropriate individual to contact for specific
questions about the work product without the need to obtain assistance
from the corresponding author.The use of standardized systems to flag each
author's contributions in the author list can also be a useful tool to help ensure
more precise recognition of each author's contribution to a work product15. One
system uses 14 specific categories to describe the contributions of individual
authors16. In circumstances where a work product includes a contribution
statement, all authors of the work product should discuss and agree on the
contributions attributed to each author.
A contribution statement reduces the chance of an authorship dispute because
it promotes open discussion about who contributed what. A contribution
statement also discourages authorship abuse. Finally, a contribution statement
provides transparency and accountability for the work product, and is another
way of reaffirming each author's responsibility for the published content.
Authorship Agreements
A written authorship agreement can be another useful tool to minimize
authorship disputes and authorship abuse. An authorship agreement
verifies that each author meets the criteria for authorship, agrees with the
contributions attributed to their name, and accepts responsibility for the work
product.The National Institutes of Health's Office of the Ombudsman equates
a written authorship agreement to a "prenuptial" agreement17.
If an authorship agreement is used, all authors of the work product should
participate in the agreement. An authorship agreement does not need to be
formal or complicated. Responses by all authors to a simple email message
from the primary author can be sufficient in many circumstances.
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8. Authorship. .....
Kespor ¦ bilities
Authorship is both an honor and a responsibility. Authorship confers
recognition that can be an essential measure of job performance and
necessary for career advancement. However, authorship also denotes
responsibility for the accuracy and quality of the work product, as well as
liability for misconduct associated with its content.
The third criterion for authorship is for the individual to approve the final
version to be published and to agree to be accountable for all aspects of the
work product. All authors are responsible for the overall accuracy, editorial
quality, and intellectual content of the work product. All authors are responsible
for taking appropriate action if they believe any part of the work product
involves plagiarism, falsification, or fabrication. Federal employees are also
responsible for complying with federal ethics laws and regulations regarding
misuse of federal position, loss of impartiality, and conflicts of interest
(Section 12). Authors should not use or report information obtained privately
though conversation, correspondence, or discussion with third parties without
explicit permission from the investigator with whom the information originated.
Information obtained in the course of confidential services such as refereeing
manuscripts or grant applications should be treated similarly. Authors are
responsible for meeting their obligations and commitments in a timely and
professional manner, even those authors "buried" between first and last author.
Authors should be aware of any data sharing responsibilities imposed by EPA18
and the agency or institution of their co-authors.The goal of data sharing is to
promote transparency and ensure the integrity and defensibility of EPA's work
products. Individuals or groups at EPA who collaborate with individuals or
groups at other institutions should consider the data sharing policies of each
institution early in the project to avoid conflicts and project delays. Authors
should also considerthe data sharing policies of the planned publication
venues to avoid unexpected conflicts or delays in publishing the work product.
"Authorship conters recognition that can be
an essential measure ot job performance
and necessary for career advancement.
However, authorship also denotes
responsibility for the accuracy and quality of
the work product, as well as liability for
misconduct associated with its content."
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9. Trainees, Technicians,
anc C xractors
The prospect of authorship should be extended to more junior members of a
research team whenever possible. An important best practice is have early
conversations with trainees and technicians to offer opportunities to fulfill the
authorship criteria in Section 2.
Trainees
Students, postdoctoral fellows, and interns and other trainees (hereafter
referred to as "trainees") can be an important part of a project team. However,
having trainees on a project team can also lead to authorship abuse. Because
trainees are typically at an early stage in their career and are appointed
for a limited period of time, they are sometimes viewed as subordinate by
other members of the project team who have more experience and seniority.
Nevertheless, the same authorship criteria apply to all members of a project
team including trainees. Authorship on any EPA work product should always
represent the significance of the individual's contribution to the work product
regardless of institutional status.
Trainees often rely on the recommendations of more senior members of the
project team for future job opportunities and career advancement.The power
disparity between trainees and senior members of a project team can lead
to trainee reluctance to dispute authorship assignments the trainee believes
are unfair or inconsistent with EPA's Authorship Best Practices or Scientific
Integrity Policy. All authors are responsible for taking appropriate action if they
believe that they have identified any type of authorship abuse associated with
the work product.
"Authorship on any EPA work product
should always represent the significance of
the individual's contribution regardless of
institutional status."
Technicians
Technicians are subject to the same authorship best practices as all other
members of a project team. A technician should be listed as an author if
the technician fulfilled all of the authorship criteria described in Section 2.
However, simply performing routine tasks does not qualify a technician for
authorship.
-------
The possibility of authorship can be a powerful
incentive that enhances employee engagement.
If a technician and their supervisor agree that
the technician is a candidate for authorship on a
work product, the supervisor should encourage
the technician early in the project to engage in
the full spectrum of intellectual activities that
result in meeting all authorship criteria.
Contractors
Project contributors who work under an EPA
contract and are not federal employees are
subject to the same authorship best practices
as other members of the project team. Because
naming contractors as authors could create
the appearance of a contractor performing an
inherently governmental function, the EPA
Acquisition Regulations19 require the clauses
specified in Appendix 2 to be included in any
contract that could result in the publication of
work performed under the contract. In addition,
the text, "Contractor's role did not include
establishing Agency policy," must also be
included in any work product that lists authors
who worked under an EPA contract.
13
Box 4: Assuming . ,
Authorship
Example You are a laboratory technician
working on a project that requires the use
of a highly specialized instrument. You
know the instrument very well because
you used it for your master's thesis and
published your work in a peer reviewed
journal. Even though the other members
of the project team are senior scientists
and you don't know much about the project
itself, you are put in charge of collecting
the data for the project because of your
expertise using the instrument. You
finally finish collecting all of the data
after many hours of hard work. Because
you have already published work using
this instrument, and you used the same
instrument to collect all of the data for this
project, you assume that you will be listed
as an author on the publication for this
project and begin work on another project.
A few months later, you find out that the
other members of the project team wrote
a manuscript and you were not listed as
an author. Is this consistent with EPA's
Authorship Best Practices?
Answer: It is complicated. Collecting data
by operating an instrument does not alone
confer authorship on the resulting work
product. Rather than assuming authorship,
it would have been wise for you to discuss
your expectations of authorship with
your supervisor early in the project. Such
a discussion may have resulted in an
opportunity to work more closely with the
project team and fulfill all of the criteria
necessary for authorship.
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10. Common Authorship
Abuses
Honorary, gift, guest, or courtesy authorship, ghost authorship, surprise
authorship, duplicate production authorship, and anonymous authorship
are common abuses of authorship. All of these types of authorship are
unacceptable.
. Honorary, gift, guest, or courtesy authorship is authorship given to an
individual who does not meet the criteria for authorship.This type of
authorship is provided for a variety of reasons. Sometimes authorship is
provided to a senior figure who expects or demands it because he/she is in
a position of authority (e.g. branch chief, division director, or office director)
or controls the project's funding. Authorship is sometimes improperly
provided to senior figures to enhance the perceived credibility of the work
product or increase the likelihood of acceptance. Honorary, gift, guest, or
courtesy authorship also occurs when a legitimate author adds another
individual to the author list with the understanding that the additional
individual will do the same in the future (or had already done so previously)
in order to inflate the publication lists of both individuals.
• Ghost authorship is the failure to give authorship to an individual who
meets the criteria for authorship. Ghost authorship is also sometimes used
to purposefully obfuscate the involvement of an individual or institution in a
work product.
"If a work product contains the same or
substantially overlapping material that was
previously disseminated, the work product
must identify the duplicate material and cite
the original source. "
• Surprise authorship is when an individual finds that he/she has unknowingly
been given authorship for a work product without having contributed to the
work or accepted responsibility for the publication's content.
• Duplicate production authorship is when material is publicly disseminated
that is the same or substantially similar to material previously
disseminated without a clear, visible reference to the original material.
Duplicate production authorship is a form of self-plagiarism (see Section
11). If a work product contains the same or substantially overlapping
material that was previously disseminated, the work product must identify
the duplicate material and cite the original source. Publication of material
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that was previously published in preliminary
form such as an abstract, poster or platform
presentation at a scientific meeting, or a
letter to the editor, is not considered duplicate
production authorship or self-plagiarism.
When preliminary work is disseminated,
authors of subsequent related work should
make the prospective publisher or audience
aware of all directly related reports already
presented, published, submitted for
publication, or in press. Most journals will not
accept material for publication if that material
has already been published or submitted to
another journal for publication.The reuse of
significant portions of one's own work without
citing the original work is self-plagiarism and
is discussed in Section 11.
Anonymous authorship. Normally it is not
appropriate to use pseudonyms or to publish
scientific or technical reports anonymously.
In rare cases when an individual can make a
credible claim that revealing his or her name
as an author could cause serious hardship
(e.g., threat to personal safety or loss of
employment), anonymous content might be
appropriate.The Scientific Integrity Official is
available to help make such determinations.
Filial or family authorship occurs when
an EPA author includes a relative (e.g., a
child or spouse) as an author without first
consulting with an ethics official. Because
working as part of one's official duties with
a family member raises concerns about loss
of impartiality and/or conflicts of interest,
employees should consult with their own
ethics officials or the Office of General
Counsel/Ethics in advance.
15
Box 5: Spousal
Privilege
Example: You and your spouse, who is a
scientist for a consulting company, decide
to write and publish a review article about a
topic in which you both have expertise.Your
spouse's employer readily agrees to allow
him to write the review with you. You pursue
this writing project in your official capacity,
but do not mention that your spouse is the
co-author. Because you do not share the
same surname, no one at EPA notices the
connection. Is that a problem?
Answer: Yes, this situation presents
an ethical issue because your spouse is
working with you under the aegis of his
company, and is being paid by his company
to do so. His salary is imputed to you under
the financial conflict of interest statute,
so you would be working in your official
capacity on a project that has a direct and
predictable financial effect upon your own
interests.You need to seek advice from
an ethics official before beginning the
collaboration with your spouse.
Box 6: AllJn the
Family
Example: Your son is a brilliant high
school student who is keenly interested in
environmental issues. You realize that he
could easily perform fact checking for your
EPA work product, thereby gaining some
experience and possible authorship. Is this a
problem?
Answer: Yes, because you have a "covered"
relationship with your son under the
impartiality standards, and cannot work
with him in your EPA capacity unless you
first receive clearance from your Deputy
Ethics Official. In addition, there may be
anti-deficiency concerns with accepting
volunteer services.
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11. Plaaiariam and
agiarism
agiar,
EPA's Policy and Procedures for Addressing Research Misconduct20 defines
plagiarism as "the appropriation of another person's ideas, processes, results,
or words without giving appropriate credit." An individual who knowingly
publishes the intellectual work of another without appropriate credit has
committed plagiarism. The Policy and Procedures for Addressing Research
Misconduct requires the reporting of such actions to the Office of Inspector
General (OIG). OIG has delegated some of the authority to resolve allegations
of plagiarism to the Scientific Integrity Official21.
Plagiarism can occur in a range of forms. Verbatim, near-verbatim copying, or
very close paraphrasing of text or results from another work is more clear-cut
than inadequacy in citing relevant works or ideas. When considering whether
or not a citation might be needed, questions such as the following can help
authors assess whether omission of a citation might constitute plagiarism22.
• Does the omission of a citation give a false or misleading impression
that you are the originator of the finding or idea?
• Are you aware of a work that can be cited for the finding or idea?
. Is the finding or idea essential to the work you are presenting?
. Is the finding or idea regarded as common knowledge?
The distinction between plagiarism and an authorship dispute may sometimes
be unclear. Circumstances where intellectual property is shared among
collaborators who subsequently separate and publish without acknowledging
the contribution of their former colleague can be particularly challenging.
Authors should arrive at a consensus decision about authorship during the
early stages of a project and continue communicating after separation to avoid
this type of plagiarism.
Self-plagiarism is the reuse of significant portions of one's own work without
citing the original work.There are two distinct forms of self-plagiarism: text
recycling and redundant publication23.
"Self-plagiarism is the reuse of significant
portions of one's own work without citing the
original work."
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Text Recycling
17
Text recycling occurs when sections of the
same text appear (usually unattributed) in more
than one of the author's own work products. In
some circumstances, a small amount of text
recycling may be unavoidable. For example, the
use of similar or identical phrases describing
certain methods or techniques that are common
to multiple work products may be unavoidable
because there are a limited number of ways to
describe them. In such circumstances, authors
should cite the original work product when
using the same or similar text.There is debate
about the acceptability of text recycling in the
background or introduction section of a work
product, for example, when a work product is one
of several on a related topic or is an extension of
previous related work24. Authors should generally
avoid text recycling. Where text recycling is
unavoidable, however, authors must cite the
original source.
Whether a small amount of text recycling is
acceptable primarily depends on whether the
source of the recycled text is properly cited,
whether the work product is original research
or a review of existing work, and whether there
is a breach of copyright.Text recycling without
attribution is unacceptable in the results,
discussion, and conclusion sections of papers
or presentations, especially if it duplicates
previously published data or results.There may occasionally be legitimate
reasons to include previously published data and results, such as when
reporting on an extension of previous studies. However, such duplication
must be clearly reported as previously published material, properly cited, and
compliant with all copyright requirements. Although the amount of repetition
deemed acceptable is unsettled, authors should always clearly acknowledge
the use of text that is identical or similar to the text that the author has used
elsewhere.
Redundant Publication
Redundant (or duplicate) publication generally refers to the repeated
publication of data or ideas without disclosing earlier publication of the
material. Redundant publication of data without attribution is always
unacceptable. Redundant publication wastes limited resources because it
displaces the publication of novel scientific finding. Presentation of material
already published or presented can also impede scientific progress because it
Box 7: Repeat
Review
Example: You are asked to write a review
paper on a topic related to your EPA work.
Your supervisor agrees that you may do this
work as part of your official duties. You write
the review using multiple long passages
from a previous review article that you wrote
as a book chapter. After all, these are your
works, so this seems okay. Is this consistent
with EPA's Authorship Best Practices?
Answer: No.This is self-plagiarism.You
should have told both those who asked you
to write the review and your supervisor of
the existence of the previous book chapter
review. If they still asked for and approved
the new review, then you should have either
paraphrased or put the passages from
your previous review in quotes, and been
transparent about where they came from.
Attribution is the key to avoiding self-
plagiarism.
-------
prevents or delays the timely dissemination of new and potentially important
scientific findings. Redundant publication can also lead to the distortion of
scientific evidence through erroneous meta-analyses. Some professional
organizations and scientific journals permit the submission of material that
expands on a previously published, brief, preliminary or incomplete account of
the same work. However, authors should notify the meeting organizer or journa
editor of the earlier publication at the time of submission, and the earlier
publication should be cited in the presentation or manuscript.
If the material is copyright protected, the author's permission for reproduction
from the copyright holder (if the copyright has been transferred to the
publisher) should be obtained, in addition to citing the original material.
Although there are no copyright requirements that apply to government
publications, authors should nonetheless avoid copying text from government
documents without attribution. When a work product includes previously
published material, the best practice is transparency - putting editors, meeting
organizers, readers, and audiences on notice to exactly which portions of a
work product are new and which are restated from elsewhere.
"When a work product includes previously
published material, the best practice is
transparency - putting editors, meeting
organizers, readers, and audiences on
notice to exactly which portions ot a work
product are new and which are restated
trom elsewhere,"
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12. Conflict of Interest,.,
& Loss of Impartiality
Conflict of Interest
All EPA employees must comply with federal ethics laws and regulations25.
One of the basic principles of ethical conduct is the avoidance of actual
or apparent conflicts of interest. Conflicts of interest are prohibited by a
criminal statute found at Section 208 of Title 18 of the United States Code26.
A conflict of interest can arise when an individual developing an EPA work
product is financially tied to the work product. Financial ties could be direct,
or to another individual or to a regulated entity that is directly affected by
the work product. You cannot work in your official capacity on any matter that
will have a direct and predictable effect upon your own financial interests or
the financial interests of your spouse or dependent minor child.This financial
conflict of interest prohibition also applies if you know that the work will affect
the financial interests of your general partner, or of an organization for which
you serve as an officer, director, employee, general partner, or trustee. It even
applies when you know that the matter will affect the financial interests of
someone with whom you have an arrangement for employment, or with whom
you are negotiating for employment.
19
Authorship establishes accountability as well
as credit. Authorship helps establish the identity
of those who are responsible for the information
and conclusions of EPA work products and
helps provide the public with a mechanism
to ensure EPA work products are developed
without conflicts of interest. By definition, an
individual with an actual or apparent conflict
of interest cannot author an EPA work product
because federal ethics laws and regulations
preclude them from working on the project
and thus fulfilling the criteria for authorship.
Conflict of interest laws and regulations even
preclude EPA employees with a conflict of
interest from being part of any group authoring
an EPA work product or working on any particular
assignment that could justify being included in
the acknowledgments.
Box 8: Taldna
Example: You inherit stock worth $26,000
in a company that manufactures a particular
chemical.There are lots of other companies
that manufacture this same chemical.
You're not sure what to do with the stock,
so you just ignore it while working hard on
a research paper about the toxicological
effects of that same chemical in drinking
water. Is this a problem?
Answer: Yes. Even if there are other
companies that manufacture this same
chemical, your ownership interest is greater
than the regulatory de minimis level.
You cannot own more than $25,000 in any
particular entity and still work on matters
of general applicability, which is what this
example describes.
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Loss of Impartiality
Another basic EPA principle of ethical conduct is remaining impartial when
performing Government duties. A loss of impartiality may arise when an
individual working on an EPA work product has non-financial ties to another
individual or entity that is directly affected by it.Thus, employees cannot as
part of their official duties engage in work on specific projects with persons or
entities with whom they have a "covered" relationship27. Examples of covered
relationships include relatives, members of your household, organizations in
which they are active participants, and former employers within the last year.
They also include the employer of your spouse, parents or dependent children,
as well as their potential employers if they are seeking employment with them.
Contributions to Agency work products by individuals or groups with actual
or perceived conflicts of interest or loss of impartiality compromise the
integrity of those work products.The success of any work product depends
upon maintaining the confidence of the public.The public could be concerned
that authors of a work product with ethical constraints may be motivated by
considerations other than the desire to do what is best for the public as a
whole.The ethics rules do not yield to assertions that individuals are certain
that they can maintain their objectivity, and neither do the concerns about
a loss of scientific integrity. All project contributors must vigilantly avoid
conflicts of interest or loss of impartiality in all aspects of a project including
the planning, execution, writing, review, and dissemination of the work product.
You are advised to consult with an ethics official if you have any questions.
"Contributions to Agency work products
by individuals or groups with actual or
perceived conflicts of interest or loss of
impartiality compromise the integrity of
those work products."
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13. Bias
Bias, although not a federal ethics issue, is
nonetheless an important scientific integrity
issue that should be considered when developing
any EPA work product. Bias is any tendency
that prevents unprejudiced consideration of a
question. Bias can occur at any stage of a project.
In research, bias occurs when "systematic
error [is] introduced into sampling or testing
by selecting or encouraging one outcome or
answer over others."28 Although an exhaustive
discussion of research bias is beyond the scope
of these best practices, all authors should strive
to be aware of their own biases and the biases
of their co-authors. Authors can reduce the
impact of bias by collaborating with and seeking
reviewfrom individuals not intimately involved
with the project, and/or with a broad spectrum
of knowledge, beliefs, and experiences29. Bias
compromises the integrity of the work product. It
is the responsibility of all authors to minimize the
impact of bias.
21
Box 9: Diverse Points
otView
Example: You and your research team
study a topic that is not well-known or
widely studied within EPA. Over the past
few years, your team has sent research
papers to the same core group of experts for
review and edits. Last month, you sent your
most recent research paper to this group of
experts for review.Today, you received their
notes and there are very minimal changes
and comments.The group of experts stated
that once these minor edits are addressed,
the paper is ready for publication. Is this
consistent with EPA's Authorship Best
Practices?
Answer: No. By sending your papers to the
same limited group of reviewers every time,
you are preventing the detection of possible
bias in your research. You should seek a
diverse group of reviewers to examine your
findings. Experts with a broad spectrum of
knowledge, beliefs and experiences are more
likely to suggest new ways of looking at the
data. It is the responsibility of all authors to
minimize bias.
"Bias is any tendency that prevents unprejudiced
consideration of a question"
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14. Copyright
Is je$?
Authors frequently desire to reuse previously published images and other
copyrighted material. It is the author's responsibility to follow journal or
publisher guidelines on the reuse and attribution of copyrighted material.This
includes the author's own work if the copyright was transferred to a publisher
or journal30. Authors should contact the journal or publisher of the source
material or consult the "permissions" information that can be found on many
of their web sites. Permission should be obtained in writing and the authors
should retain this documentation.The publisher of the reused material may
request a copy of this notification as well.
Works created by federal employees as part of their official duties cannot
be copyrighted in the United States. Upon acceptance of information for
publication and receipt of a copyright transfer form from a publisher, federal
authors should sign the form where it specifies that they were a federal
employee when the work was prepared and thus there is no copyright to
transfer. When both federal and nonfederal employees are authors of the same
work product, each author should sign the appropriate section of the copyright
transfer form.
"Works created by federal employees as part of their
official duties cannot be copyrighted in the
United States."
Although the content of a publication authored by federal employees may not
be copyrighted, some publications (e.g., journals) may copyright the format in
which the information is published.The copyright on format may inhibit EPA's
ability to freely copy the published information. If the publication is of such a
nature that wide distribution is desirable, the authors should seek a license
from the publication to freely copy and distribute the information as it was
published.This license should be negotiated prior to publication. EPA's Office
of General Counsel Intellectual Property Law Practice Group is available to
assist in this process.
For further information on copyright related issues, please consult the
Publication Agreement Frequently Asked Questions31 from the Office of
General Counsel webpage.
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Appendix 1
Office of the Science Advisor
Coordination Procedures between the Scientific Integrity Official and the
Office of Inspector General regarding Research Misconduct Allegations
March 30, 2015
Introduction and Purpose
The Scientific Integrity Official and the OIG will rely on the following
authorities in interpreting the division of responsibilities and actions in these
procedures:
. EPA Order 3120.5 Policy and Procedures for Addressing Research
Misconduct.
• Section 7 of the EPA Order 3120.5 outlines the circumstances when the
OIG must be notified immediately.
• Section 9 A of EPA Order 3120.5 requires EPA employees to promptly
report allegations of research misconduct by EPA personnel.
Forthe purposes of this document, the term Research Misconduct Allegation
is defined, according to EPA Order 3120.5, "Policy and Procedures for
Addressing Research Misconduct,"32 as, "fabrication, falsification, or
plagiarism in proposing, performing or reviewing research, or in reporting
research results, or ordering, advising or suggesting that subordinates engage
in research misconduct." Research misconduct does not include honest error or
differences of opinion.
I. Notification Upon Receipt of an Allegation of Research Misconduct
1. Upon receipt of a research misconduct33 allegation, the Scientific
Integrity Official will, within seven calendar days: a) refer the
allegation to the Office of Inspector General (OIG) Hotline.
2. If the OIG or the OIG Hotline receives an allegation of research
misconduct, within 7 days, the allegation will be forwarded to the
OIG Hotline which will contact the Scientific Integrity Official to
discuss the allegation, as appropriate.
II. Determining Which Office Will Address the Allegation of Research
Misconduct
1. The OIG agrees that the U.S. EPA Scientific Integrity Official will
evaluate allegations of plagiarism (except in the circumstances listed
in EPA Order 3120.5, Section 7), including making inquiries and
writing reports summarizing the findings of those inquiries.The
Scientific Integrity Official will then share the report with the OIG
and take actions necessary to secure the science. If during an inquiry
into a plagiarism allegation, the Scientific Integrity Official discovers
there is a potential criminal aspect to the allegation (false statement,
-------
fraud or theft) to the allegation which was not apparent during initial
screening, then the Scientific Integrity Official will stop its inquiry
and consult with the OIG, which will address the matter in accordance
with OIG Hotline procedures.
2. The OIG through the OIG Hotline will inform the Scientific Integrity
Official about its decision regarding disposition of research
misconduct allegations.The OIG disposition will consist of one of the
three following options:
a. There is no further OIG interest in the allegation.The OIG
Hotline will send a referral memorandum to the Scientific
Integrity Official within 5 business days of this decision.The
Scientific Integrity Official will conduct its inquiry in
accordance with its policy for resolving allegations of loss
of scientific integrity.The Scientific Integrity Official will
respond to the complainant for these allegations. The OIG
Hotline will be closed.
b. OIG needs to gather additional information prior to making a
determination regarding the disposition of the allegation, or
c. OIG will start an audit, evaluation, investigation, or other
action and will contact the Scientific Integrity Official for
assistance as needed.The OIG or the OIG Hotline will send a
notice to the Scientific Integrity Official within 5 business
days of its decision to take action on the allegation. The notice
to the SIO may be a courtesy copy of a Hotline Referral, OIG
Assignment Notification Memorandum, or electronic message.
Communications between the OIG and the Scientific Integrity Official
1. For allegations retained by the OIG, within 30 days of the receipt of
the referral, and quarterly thereafter, the OIG will inform the
Scientific Integrity Official of the status of any OIG action on the
referral.
2. For allegations addressed by the Scientific Integrity Official, the
Scientific Integrity Official will report on the status quarterly and
final documentation of the resolution of the allegation will be sent to
the OIG Hotline Coordinator.
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25
Appendix 2
CO
Contract Publication Review Procedures (APR 1984)
(a) Material generated under this contract intended for release to the public is
subject to the Agency's publication review process in accordance with the EPA
Order on this subject and the following.
(b) Except as indicated in paragraph (c) of this contract, the Contractor shall
not independently publish or print material generated under this contract
until after completion of the EPA review process.The Contracting Officer's
Representative will notify the Contractor of review completion within
calendar days after the Contractor's transmittal to the Contracting Officer's
Representative of material generated under this contract. If the Contractor
does not receive Contracting Officer's Representative notification within this
period, the Contractor shall immediately notify the Contracting Officer in
writing.
(c)The Contractor may publish, in a scientific journal, material resulting
directly or indirectly from work performed under this contract, subject to the
following:
(1)The Contractor shall submit to the Contracting Officer and the
Contracting Officer's Representative, at least 30 days prior to
publication, a copy of any paper, article, or other dissemination of
information intended for publication.
(2)The Contractor shall include the following statement in a journal
article which has not been subjected to EPA review:
"Although the research described in this article has been funded
wholly or in part by the United States Environmental Protection
Agency contract (number) to (Name of Contractor), it has not been
subject to the Agency's review and therefore does not necessarily
reflect the views of the Agency, and no official endorsement should
be inferred."
(3) Following publication of the journal article, the Contractor
shall submit five copies of the journal article to the Contracting
Officer's Representative, and one copy to the Contracting Officer.
(d) If the Government has completed the review process and agreed that the
contract material may be attributed to EPA, the Contractor shall include the
following statement in the document:
This material has been funded wholly or in part by the United States
Environmental Protection Agency under contract (number) to (name). It
C/jiD
-O
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26
has been subject to the Agency's review, and it has been approved for
publication as an EPA document. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
(e) If the Government has completed the review process, but decides not to
publish the material, the Contractor may independently publish and distribute
the material for its own use and its own expense, and shall include the
following statement in any independent publication:
Although the information described in this article has been funded wholly
or in part by the United States Environmental Protection Agency under
contract (number) to (name), it does not necessarily reflect the views of
the Agency and no official endorsement should be inferred.34
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^I^otes
1. U.S. Environmental Protection Agency Scientific Integrity Policy: http://
www2.epa.gov/sites/production/files/2014-02/documents/ scientific_
integrity_policy_2012.pdf
2. National Partnership Council, US EPA (1999) Principles of Scientific
Integrity: http://www.epa.gov/osa/pdfs/scientific-integrity-principles.pdf
3. An "EPA work product" is defined here as any deliverable or material
outcome of any activity undertaken by EPA employees in their official
capacities or by any contractor, student or other individual under the
direction and auspices of EPA.
4. U.S. Environmental Protection Agency Scientific Integrity Policy, section
II, paragraph 1: http://www2.epa.gov/sites/production/files/2014-02/
documents/ scientific_integrity_policy_2012.pdf
5. Nature Journal Authorship Policy: http://www.nature.com/authors/policies/
authorship.html
6. ACS Publications Ethical Guidelines to Publications of Chemical
Research: http://pubs.acs.org/userimages/ContentEditor/1218054468605/
ethics.pdf
7. Council of Science Editors Authorship and Authorship Responsibilities:
http://www.councilscienceeditors.org/resource-library/editorial-policies/
white-paper-on-publication-ethics/2-2-authorship-and-authorship-
responsibi I ities/
8. CDC Authorship Policy: http://www.cdc.gov/maso/policy/authorship.pdf
9. Recommendations for the Conduct, Reporting, Editing, and Publication
of Scholarly Work in Medical Journals: http://www.icmje.org/icmje-
recommendations.pdf
10. Claxton, Larry D. Scientific Authorship Part 2. History, recurring issues,
practices, and guidelines. Reviews in Mutation Research 589 (2005) 31-45.
11. ORI Publications/Authorship: https://ori.hhs.gov/publicationsauthorship
12. An author, as described here, is not the same as an author under copyright
law.The term "author" is not defined in the U.S. Copyright Act, but is
commonly considered to be one who "translates an idea into a fixed,
tangible expression eligible for copyright protection." CCN v. Reid, 490 U.S.
730 (1989).
13. Winston, Roger B. "A suggested procedure for determining order of
authorship in research publications." Journal of Counseling & Development
63.8 (1985): 515-518.
14. Recommendations for the Conduct, Reporting, Editing, and Publication
of Scholarly Work in Medical Journals: http://www.icmje.org/icmje-
recommendations.pdf
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28
15. Singh, Chawla D. "Digital badges aim to clear up politics of authorship."
Nature 526.7571 (2015): 145-146.
16. Allen, Liz, et al. "Credit where credit is due." Nature 508.7496 (2014): 312-313.
17. Preempting Discord: Prenuptial Agreements for Scientists By Howard
Gadlin, NIH Ombudsman, and Kevin Jessar, NIH Associate Ombudsman
18. EPA Website: http://www.epa.gov/open/
19. United States EPA Acquisition Regulation: http://govcon360.com/wp-
content/uploads/2012/09/EPAAR-12020607.pdf
20. Policies and Procedures for Addressing Research Misconduct. EPA Order
3120.5: https://www.epa.gov/sites/production/files/2014-04/documents/
epapolicy.pdf
21. Coordination Procedures between the Scientific Integrity Official and the
Office of Inspector General regarding Scientific Misconduct Allegations:
http://www.epa.gov/osa/coordination-procedures-between-scientific-
integrity-official-and-office-inspector-general
22. Adapted from: SIAM: Authorial integrity in scientific publication, (n.d.):
http://www.siam.org/books/plagiarism.php.
23. Committee on Publication Ethics:Text Recycling Guidelines: http://
publicationethics.org/text-recycling-guidelines
24. How to deal with text recycling, (n.d.): http://media.biomedcentral.com/
content/editorial/BMC-text-recycl ing-editorial_guidelines.pdf
25. The Ethics Program: http://intranet.epa.gov/ogc/ethics.htm
26. Bribery, Graft, and Conflict of Interest: https://www.gpo.gov/fdsys/pkg/
USCODE-2009-title18/html/USCODE-2009-title18-partl-chap11-sec208.htm
27. See 5 C.F.R. Section 2635.502(b)
28. Definition of Bias: http://www.merriam-webster.com/dictionary/bias
29. Claxton, L.D. A Review of Conflict of Interest, Competing Interest, and Bias
forToxicologists.Toxicology and Industrial Health 2007; 23:557-571.
30. Unless the work was a U.S. government work, in which case there would not
have been a U.S. copyright to transfer.
31. Frequently Asked Questions about Publication Agreements: http://intranet.
epa.gov/ogc/ethics/docs/Publication-agreement-FAQs.docx
32. EPA Order on Policy and Procedures for Addressing Research Misconduct:
http://www2.epa.gov/programs-office-science-advisor-osa/epa-order-
policy-and-procedures-addressing-research-misconduct
33. As defined by EPA Order 3120.5
34. CFR 1552.237-70
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Scie
ific Int
on
ity Committee
o ation*
Office/Region
Official
Email
Scientific Integrity Official
Francesca Grifo
grifo.francesca@epa.gov
Scientific Integrity Program Lead
Martha Otto
otto.martha@epa.gov
OAR
Betsy Shaw
shaw.betsy@epa.gov
OARM
Lynnann Hitchins
hitchins.lynnann@epa.gov
OCFO
David Bloom
bloom.david@epa.gov
OCSPP
Louise Wise
wise.louise@epa.gov
OECA
Tom Norris
norris.tom@epa.gov
OEI
Steven Fine
fine.steven@epa.gov
OGC
Carol Ann Siciliano
siciliano.carolann@epa.gov
OITA
Randy Hill
hill.randy@epa.gov
AO
Al McGartland
mcgartland.al@epa.gov
ORD
Robert Kavlock
kavlock.robert@epa.gov
OLEM
Barry Breen
breen.barry@epa.gov
OW
Mike Shapiro
shapiro.mike@epa.gov
AO
John Reeder
reeder.john@epa.gov
OSA
Mary Greene
greene.mary@epa.gov
Region 1
Robert Maxfield
maxfield.robert@epa.gov
Region 2
Anahita Williamson
williamson.anahita@epa.gov
Region 3
John Forren
forren.john@epa.gov
Region 4
Marilyn Maycock
maycock.marilyn@epa.gov
Region 5
Carole Braverman
braverman.carole@epa.gov
Region 6
David (Wes) McQuiddy
mcquiddy.wes@epa.gov
Region 7
CeciliaTapia
tapia.cecilia@epa.gov
Region 8
DebThomas
thomas.debrah@epa.gov
Region 9
Eugenia McNaughton
mcnaughton.eugenia@epa.gov
Region 10
David Allnutt
allnutt.david@epa.gov
*As of July 2016
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http:ll www. epa.govlscientificintegrity
To report allegations or concerns:
http://www2.epa.gov/osa/forms/anonymous-scientific-integrity-concerns-and-suggestions
Scientific Integrity Official Scientific Integrity Program Lead
Francesca T. Grifo, PhD Martha Otto
Grifo.francesca@epa.gov Otto.martha@epa.gov
(202) 564-1687 (202) 564-2782
To report fraud, waste or abuse, contact the hotline (Office of Inspector General):
E-mail: OIG_Hotline@epa.gov
Phone: 1-888-546-8740
Fax: 202-566-2599
Online: http://www.epa.gov/oig/
hotline.htm
Write:
EPA Inspector General Hotline
1200 Pennsylvania Avenue NW
Mailcode 2431T
Washington, DC 20460
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