Scientific Integrity Concerns
The Presidential Memorandum on Scientific Integrity (March 9, 2009) directs that "Each
agency should have in place procedures to identify and address instances in which the
scientific process or the integrity of scientific and technological information may [have
been] compromised." EPA's Scientific Integrity Policy requires "mechanisms to ensure
accountability." Allegations may be reported to the Scientific Integrity Official, any
Deputy Scientific Integrity Official, or the Inspector General Hotline.
In FY 2018, the Program drafted a new procedure creating a two-pronged approach
separating those seeking advice about scientific integrity concerns from those reporting
allegations. In general, the new advice track was designed to resolve concerns before
they became a formal allegation by giving informal and early counsel. Eight allegations
and 93 requests for advice were received during FY 2021.
Advice Lane
The aim of the advice track is early preventive action to uphold EPA's culture of
scientific integrity. Anyone with a question or a concern is encouraged to have a
conversation with the Scientific Integrity Official (Francesca Grifo), the Deputy to the
Scientific Integrity Official, or any of the Agency's Deputy Scientific Integrity Officials in
each program or regional office. These officials can provide timely advice or assistance.
If the issue is not one of scientific integrity, they can assist in redirecting it as
appropriate such as directing retaliation, waste, fraud or abuse to EPA's Office of the
Inspector General. If advice and assistance do not resolve the issue, an allegation may
be filed with the Scientific Integrity Official. Deputy Scientific Integrity Officials, or the
EPA's Office of Inspector General. Following the development of the two-track
procedure described in Box 1 below, the Scientific Integrity Program reviewed all prior
allegations and reclassified many of them as requests for advice.
Allegations
When advice does not resolve an issue, is not appropriate or an issue is novel or
complex, employees may file an allegation. If an issue concerns an unaddressed
significant risk to public health or the environment, submitters are directed to EPA's
elevation procedures or the Office of Inspector General.
Any covered entity (employees, political appointees, contractors, trainees, interns,
fellows, grantees, volunteers, special government employees and advisory committee
members) within EPA may report an allegation to the Scientific Integrity Official, any
Deputy Scientific Integrity Official, or the Office of Inspector General. To allow the
Scientific Integrity Official or Deputy Scientific Integrity Official to more efficiently
address allegations, allegation reports should include, when possible, detailed
references to the specific provision(s) of EPA's Scientific Integrity Policy that were
violated, supporting evidence with a timeline, and the names of witnesses who can
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provide pertinent information. Once received, the Scientific Integrity Program screens
the allegation, gathers additional pertinent information, and makes a determination
based on the available information, drawing on the experience and expertise of the
Scientific Integrity Committee as needed. The determination includes recommendations
for corrective scientific action and other preventive measures as appropriate.
Recommendations are not directed at individual employees but rather at safeguarding
the science. Relevant managers and supervisors are informed of the outcomes of
allegations as disciplinary and other corrective actions are their responsibility, and not
within the purview of the Scientific Integrity Program. Throughout the process,
confidentiality is maintained to the extent the law allows and knowledge about the
identity of persons submitting or otherwise involved in the allegation is limited to those
who need to know.
Box 1. Advice or Allegation?
Advice or Allegation?
Advice
¦ First conversation.
¦ Is it scientific integrity?
• Next steps are clear.
• Informational conversation.
• Not high profile or directly linked to a threat to public health.
• Can be anonymous.
Allegation
• Based on current information, it would be a violation of the Policy.
• The submitter is aware of our limitations on confidentiality and wishes to proceed.
• Advice is not appropriate.
¦ Previous advice was not effective or effective enough.
• Urgent or high profile.
• Expertise or support of the Scientific Integrity Committee is warranted.
Annual Update on Allegations and Advice
Advice and Allegations Through FY 2021
Between February 2012 and September 30, 2021, there have been 328 requests for
advice and 109 allegations. Figure 3 illustrates allegations, indicated in green, and
advice requests, indicated in blue, by year since the Policy was adopted. For a
breakdown of submissions by quarter, see Figure 4.
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Advice and Allegations by Fiscal Year
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Figure 2. Number of advice and allegations received by quarter
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Requests for Advice in Fiscal Year 2021
In FY 2021, we received 93 requests for advice (Figure 5). These ranged from
questions about delay and suppression of scientific products (5%) to inappropriate
interference (41%). Figure 6 details requests for advice in FY2012-2020.
FY 2021
Other
Figure 3. Request for advice in FY 2021 (N=93)
Note* Anything less than 5% of the total was included in other (Quality Assurance, Retaliation, Conflict of
Interest, Differing Scientific Opinion, Professional Development, Misconduct, Peer Review, Data Quality)
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FY 2012-2020
Peer review Plagiarism Retaliation
Figure 4. Requests for advice from FY 2012-2020 (N=235)
Increase in Categories
There was a significant increase in number of requests for advice, along with an
expanded number of categories used to classify them during FY 2021. This may be due
to employees becoming more comfortable with reaching out to the Scientific Integrity
Official or their Deputy Scientific Integrity Official for advice, and therefore deescalating
the situation before an allegation would need to be made. For example, the general
advice category increased from 2% of all queries in the years leading up to FY 2021 to
10% in FY 2021.
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What is Interference?
The altering of scientific products without scientific justification. For example:
Manipulation of science used in decision making;
Removing studies, cherry picking studies for inclusion, or narrowing the scope of the science
without scientific justification;
Rejection of models, new methods, information, or procedures;
Downplaying or exaggerating uncertainty;
Using inadequate, outdated, or substandard science;
Risk management considerations driving risk assessment decisions;
Changes to minimize risk conclusions or removal of hazards in assessments.
Summary of Allegations in FY 2021
Allegations in FY 2021
In FY 2021, the Program received 8 allegations (Figure 7). This is a decrease from the
17 allegations received in FY 2020. These ranged from allegations regarding peer
review and attribution to interference. Figure 8 breaks down the status of allegations
between FY 2012- 2020.
FY 2021
Retaliation
13%
Figure 5. Allegations by topic FY 2021 (N=8)
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Peer Review
FY 2012-2020
other
Authorship
Not SI
10%
Data quality
8%
Delay/Suppression
16%
Interference
35%
Figure 6. Allegations by Topic FY2012-2020 (N=101)
FY 2021 Allegation Status
Withdrawn
Figure 7. Status of Allegations (as of the end of FY 2021) (N=109)
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Increase in Advice and Allegations
More than half of the allegations received in FY 2021 were in the interference category.
While the number of allegations dropped, the total number of advice and allegations
continued to rise from 73 in 2020 to 101 in 2021.
Status of Allegations
The status of allegations throughout the Program's entirety can be found in Figure 9.
Summary of Closed Allegations in FY 2021
One allegation was closed during FY 2021. A summary of the allegation adjudicated
during FY 2021 is detailed below.
A Differing Scientific Opinion (DSO) was submitted by a group of scientists in a Program
Office. Typically, the submission of a DSO is not considered an allegation of a lapse in
scientific integrity as a DSO is a legitimate part of the scientific process. However, two
of the authors of this DSO alleged that their concerns had not been adequately
considered by their Program Office management.
The Program Office management acknowledged that the processes outlined in EPA's
"Approaches for Expressing and Resolving Differing Scientific Opinions" had not been
adequately applied in relation to this DSO; therefore, this allegation is substantiated.
The Program Office agreed to apply the processes described in "Approaches for
Expressing and Resolving Differing Scientific Opinions" to this and any future DSOs.
Office of Inspector General Report on Scientific
Integrity
On May 20, 2020, EPA's Office of Inspector General (OIG) issued the report #20-P-
01734, "Further Efforts Needed to Uphold Scientific Integrity Policy at EPA." The report
examined whether the EPA's Scientific Integrity Policy was being implemented as
intended to assure scientific integrity throughout the EPA. The OIG audit examined the
"extent and type of employee concerns with SI at the EPA; employee awareness of
EPA's SI Policy, including the process for reporting potential violations; reasons
potential violations may not be reported; and the adjudication process for allegations of
SI Policy violations."
The report included recommendations of actions designed to help the Scientific Integrity
Official, the Committee, Office of the Administrator, and other offices consistently
implement the Scientific Integrity Policy across the Agency such as finalizing
procedures to address allegations of scientific integrity violations, tracking mandatory
scientific integrity training, and supporting release of scientific products through a
centralized clearance system. The Program adjusted its work plan to implement
corrective actions in response to the report's recommendations.
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In FY 2021, EPA completed four recommendations: developed and implemented a
resource plan that addressed the action items in Appendix A (of the OIG Report #20-
0173); incorporated summaries of allegations of scientific integrity violations (as
applicable and to the extent that privacy allows) in annual reporting; developed a
timeline to ensure the prior fiscal year annual report by the Agencywide annual meeting
on Scientific Integrity (03/31/2021); and, posted prior year Annual Reports (2018, 2019)
on Scientific Integrity to the EPA's public website. As detailed in Figure 7, EPA is
continuing work to address the remaining recommendations.
No.
OIG Recommendation
EPA
Status
1
Determine the extent and cause of the culture and "tone at the top"
concerns, based on the indicators from the OIG's scientific integrity
(SI) survey. Issue the results to all EPA staff and make available to
the public.
On track
2
With the assistance of the Scientific Integrity Committee (SIC),
develop and identify which performance measures will be used to
define SI Program success and effective Scientific Integrity Policy (SI
Policy) implementation.
On track
3
With the assistance of the SIC, develop and execute a plan, including
resource needs and milestones, to address the remaining action
items identified by the agency to improve the implementation of its SI
Policy." (Appendix A)
Completed
4
In coordination with OMS and the SIC, develop and implement a
process for tracking completion of SI training for all new employees,
including senior leadership and political appointees
Completed
5
Provide updated information on SI training completion rates to SIC
members and supervisors.
Completed
6
In coordination with OMS, complete the development and
implementation of the electronic clearance system for scientific
products across the agency.
On track
7
With the assistance of the SIC, finalize and release the draft
procedures for addressing allegations of a violation of the SI Policy
and incorporate the procedures into SI outreach and training
materials.
On track
8
With the assistance of the SIC, develop and implement a process to
adjudicate allegations of SI Policy violations involving high-profile
issues or senior officials in the agency for which the SIO or SIC does
not feel it can adequately adjudicate via existing procedures; include
an indicator for when the process should be used.
On track
9
With the assistance of the SIC, finalize and implement a charter or
procedures to clarify the roles and responsibilities of SIC members.
Completed
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10
Include in the SI Program's annual reporting on allegations of SI
violations (as applicable and to the extent that privacy allows): (a)
adjudication outcome; (b) description of the process used to reach the
adjudication outcome; (c) description of corrective actions and/or any
longer-term changes or consequences to address the cause of
substantiated violations; (d) whether and how the allegation was
resolved through the advice/assistance process."
Completed
11
With the assistance of the SIC, finalize and post to the EPA's public
website prior year Annual Reports on SI.
Completed
12
Develop a timeline or procedure that ensures the prior fiscal year
annual report on SI is completed and distributed before the annual
agency wide meeting on SI.
Completed
Figure 10. Status of OIG Recommendations (End of FY 2021)
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