EPA Science Advisory Board: Policy Statement on Science Quality and Integrity

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What GAO Found

The Environmental Protection Agency (EPA) did not update its policies or requirements on science quality and integrity for the Science Advisory Board (SAB) in response to the direction in the explanatory statement accompanying the Consolidated Appropriations Act, 2016, nor did it specifically address all of the directives in the statement. Instead, EPA developed a draft document that describes how the SAB Staff Office implements existing policies and procedures, according to the letter accompanying this document and SAB Staff Office officials GAO interviewed. The letter accompanying the draft document provided to GAO for review was dated September 30, 2016–more than 6 months after the deadline in the explanatory statement.

The draft document EPA developed states that EPA has policies to ensure that advisory committees operate in accordance with (1) the Federal Advisory Committee Act (FACA) and its implementing regulations, (2) statutes and regulations regarding ethics requirements for members of advisory committees and panels, and (3) other relevant EPA policies, including the Scientific Integrity Policy and the Peer Review Policy. According to the draft document, EPA addresses SAB scientific quality and integrity issues–such as independence and objectivity, committee composition and balance, and freedom from financial conflicts of interest–through its Scientific Integrity Policy, Peer Review Policy, Peer Review Handbook, and the Office of Management and Budget Peer Review Bulletin. With regard to the first directive in the explanatory statement, the draft document does not include specific or numeric goals on increasing membership from states and tribes, but it states that the SAB Staff Office is committed to expanding the diversity of scientific perspectives on the SAB, including the perspectives of scientists from state and local governments, tribes, industry, and nongovernmental organizations. According to SAB Staff Office officials, while they seek to increase the participation of state scientists, they often receive few applications from these scientists and, therefore, meeting a numeric goal could be challenging. With regard to the second directive in the explanatory statement, the draft document does not discuss whether EPA’s Administrator made a decision about the appropriateness of updating financial-related metrics for identifying conflicts of interest or bias. SAB Staff Office officials said that this is because they rely on the existing legal and policy framework as appropriate financial metrics for identifying conflicts of interest or bias. With regard to the third directive in the explanatory statement, the draft document refers to but does not update the practices for considering and responding to public comments that are included in the Peer Review Handbook and the SAB handbook. GAO is not making a recommendation at this time because EPA has not yet finalized its policy statement. However, as EPA moves forward, GAO encourages it to specifically address the directives provided in the explanatory statement.

Why GAO Did This Study

In formulating rules to protect the environment and public health, EPA relies on the SAB as a source of scientific and technical advice. The SAB consists of about 45 independent experts in the fields of science, engineering, economics, and other social sciences and is overseen by the SAB Staff Office, which is staffed by EPA employees. An explanatory statement accompanying the Consolidated Appropriations Act, 2016 directed EPA to develop an updated policy statement on science quality and integrity for the SAB. According to the explanatory statement, the policy statement should include (1) goals on increasing membership from states and tribes; (2) an evaluation of potential bias, if EPA’s Administrator decides that financial-related metrics are appropriate to identify conflicts of interest or bias; and (3) direction on treating public comments. The explanatory statement also directed EPA to submit a draft of the policy statement to GAO for review.

GAO assessed whether EPA drafted an updated policy statement that addressed the directives in the explanatory statement. GAO reviewed EPA documents and interviewed EPA officials, including SAB Staff Office officials.

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