Programs of the Office of the Science Advisor (OSA)

Basic Information about Scientific Integrity

2015 Annual Report on Scientific Integrity

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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. EPA's Scientific Integrity Policy was issued in February 2012 and provides a framework to promote scientific and ethical standards and to create a proactive culture to support them. The Policy applies to all EPA employees including scientists, managers, political appointees as well as contractors, grantees, collaborators, and student volunteers.

Background on Scientific Integrity

What is Scientific Integrity?

Scientific Integrity results from adherence to professional values and practices, when conducting and applying the results of science and scholarship. It ensures:

  • Objectivity
  • Clarity
  • Reproducibility
  • Utility

Scientific Integrity is important because it provides insulation from:

  • Bias
  • Fabrication
  • Falsification
  • Plagiarism
  • Outside interference
  • Censorship
  • Inadequate procedural and information security

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Why is Scientific Integrity Important?

  • Scientific integrity helps to build public support. People are more likely to support the Agency if they can trust the quality and integrity of its work.
  • Scientific integrity, along with federal policies on research misconduct, conflicts of interest, and transparency help to ensure that EPA employees, contractors, and grantees can be held accountable to the public.
  • Since EPA reseach often involves a great deal of cooperation and coordination among many different people in different disciplines and institutions, scientific integrity promotes the values that are essential to collaborative work, such as trust, accountability, and fairness. For example, data sharing policies, and confidentiality rules in peer review are designed to protect intellectual property interests while encouraging collaboration.
  • Scientific integrity promotes the aims of research, such as knowledge, truth, and avoidance of error. For example, prohibitions against fabricating, falsifying, or misrepresenting research data promote the truth and avoid error.
  • Finally, scientific integrity promotes a variety of other important moral and social values, such as compliance with the law, and health and safety.

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Principles of Scientific Integrity

In 1999, the Agency published its Principles of Scientific Integrity, developed in conjunction with the EPA's National Partnership Council, which is comprised of representatives of Agency labor unions and management. The Principles laid out the basic rules for ethical behavior by all EPA employees in:

  • Conducting scientific research
  • Interpreting and presenting results
  • Using scientific information and data

Training was also made available at that time on the Scientific Integrity Principles.

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Executive Branch and EPA Reaffirm Commitment to Scientific Integrity

In his inaugural address in 2009, President Obama promised to "restore science to its rightful place." He followed that up a few weeks later with an executive memorandum that expressed the need for robust science to inform and guide decisions by Executive Branch departments and agencies. Shortly after this, then EPA Administrator Lisa Jackson issued a memorandum to all EPA employees in which she emphasized that science must be the compass guiding the EPA's environmental protection decisions and that the Agency cannot make the best decisions unless it has confidence in the integrity of the science on which it relies.   

In December, 2010, the White House Office of Science and Technology Policy (OSTP) provided guidance for the development of scientific integrity policies by federal agencies. The guidelines require agencies and departments to create or improve policies related to:

  • Foundations of scientific integrity in government
  • Public communications
  • Use of federal advisory committees
  • Professional development of scientists and engineers

Acknowledging differences in structure and degree of regulatory responsibility, agencies and departments were given some latitude in developing their policies.

In response to OSTP, EPA convened an ad hoc scientific integrity working group, with members from across the Agency. A few months later, EPA released its draft policy for public comment. All of the public comments were considered and, in combination with discussions with other Federal agencies, contributed to an improved final policy, which was released in February 2012.

The EPA Scientific Integrity Policy builds upon EPA's significant earlier scientific integrity efforts, focusing on the:

  • Promotion of a culture of scientific integrity throughout the EPA
  • Release of scientific information to the public
  • Consistent use of peer review and federal advisory committees
  • Professional development of government scientists

The Policy also established a Scientific Integrity Committee (the Committee) to provide oversight for its implementation. The Committee, led by the Scientific Integrity Official, encourages consistent Policy implementation and further bolsters the EPA's broader efforts to ensure the integrity of the Agency's scientific, engineering, and other technical work.

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Scientific Integrity at EPA

Overview

Scientific Integrity at EPA is the responsibility of every employee, contractor, grantee, volunteer and collaborator who conducts, utilizes, supervises, manages, communicates, or influences scientific activities. The Scientific Integrity Policy exists against a complicated regulatory backdrop. For example, the Policy works in conjunction with policies and procedures for addressing research misconduct, information quality, quality assurance, and peer review. The Policy also works in conjunction with statutes such as the Freedom of Information Act and Federal Advisory Committee Act.

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History of Scientific Integrity at EPA

While our Scientific Integrity Policy dates from 2012, EPA has a long history of attention to scientific integrity. Many EPA administrators have addressed integrity and transparency in memos to the Agency. Administrator William Ruckelshaus drafted a memo in 1983 establishing a culture of integrity, which was followed in 1989 with one by William Reilly and another in 1993 by Carol Browner. In 1999, the National Partnership Council of EPA released their Principles of Scientific Integrity. In January of 2009, President Obama pledged to "restore science to its rightful place" in his inaugural address and followed up in March of that same year with an executive memorandum on scientific integrity. The memorandum directed the White House Office of Science and Technology Policy (OSTP) to develop a plan aimed at ensuring the integrity of federal science. In May of that year, a year and a half before OSTP released its plan, then Administrator Lisa Jackson released a memorandum that declared "Science must be the compass guiding our environmental protection decisions.…While the laws that EPA implements leave room for policy judgments, the scientific findings on which these judgments are based should be arrived at independently using well-established scientific methods, including peer review, to assure rigor, accuracy, and impartiality."

In December, 2010, OSTP provided guidance to federal agencies for the development of scientific integrity policies. These guidelines required agencies and departments to create or improve policies related to:

  • Foundations of Scientific Integrity in Government
  • Public Communications
  • Use of Federal Advisory Committees
  • Professional Development of Scientists and Engineers

Acknowledging differences in structure and degree of regulatory responsibility, agencies and departments were given some latitude in developing their policies.

In response to OSTP, EPA convened an ad hoc scientific integrity working group, with members from across the Agency. A few months later, EPA released its draft policy for public comment. Public comments and discussions with other federal agencies contributed to the improved final policy.

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EPA Scientific Integrity Policy

The Agency has established, and continues to promote, a culture of scientific integrity for all of its employees. This policy provides a framework intended to ensure scientific integrity throughout the EPA and promote scientific and ethical standards, including: 

  • Quality standards
  • Communications with the public
  • The use of peer review and advisory committees
  • Professional development

View EPA's Scientific Integrity Policy

Evaluation of the Scientific Integrity Policy

EPA is developing a process to evaluate the Scientific Integrity Policy to ensure its effectiveness and adherence with applicable rules and regulations.

Scientific Integrity Committee

The Scientific Integrity Policy establishes a Scientific Integrity Committee to implement the Policy. The Committee consists of Deputy Scientific Integrity Officials that represent each of the Agency's Program Offices and Regions. The Scientific Integrity Official (ScIO) chairs the Committee. The ScIO is the Agency's focal point on scientific integrity and serves as the Agency's expert on such matters.

Francesca T. Grifo, Ph.D., EPA Scientific Integrity Official and Committee Chair

Office/Region Deputy Scientific Integrity Official
Office of Air and Radiation Betsy Shaw
Office of Administration and Resources Management Lynnann Hitchens
Office of the Chief Financial Officer David Bloom
Office of Chemical Safety and Pollution Prevention Louise Wise
Office of Enforcement and Compliance Assurance Tom Norris
Office of Environmental Information Steven Fine
Office of General Counsel Carol Ann Siciliano
Office of International and Tribal Affairs Randy Hill
Office of Policy Al McGartland
Office of Research and Development Robert Kavlock
Office of Land and Emergency Management Barry Breen
Office of Water Mike Shapiro
Office of the Administrator John Reeder
Office of the Science Advisor Mary Greene
Region 1 Robert Maxfield
Region 2 Linda Mauel
Region 3 John Forren
Region 4 Thomas Baugh
Region 5 Carole Braverman
Region 6 David (Wes) McQuiddy
Region 7 Cecilia Tapia
Region 8 Debra Thomas
Region 9 Eugenia McNaughton
Region 10 David Allnutt

Scientific Integrity Policies and Resources

EPA has many clearly articulated policies and procedures in place that relate to scientific integrity. These enhance the culture of scientific integrity at EPA and protect against scientific misconduct by any Agency employees, including managers and other Agency leadership. In an effort to help employees find the right source of further information, we provide links for the policies, statutes, and other resources below.

Scientific Integrity Annual Report

OSA issued its second Annual Report on Scientific Integrity on March 2, 2015. The Annual Report highlights:

  • Scientific integrity milestones at EPA
  • Ongoing and new scientific integrity activities in FY2014
  • Scientific integrity accomplishments in FY2014
  • Opportunities for improvement
  • Areas for future investment

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Coordination Procedures for Misconduct Allegations

Coordination Procedures were developed with the Office of Inspector General to promote the efficient evaluation and disposition of decisions regarding scientific misconduct allegations.

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Other EPA Products and Publications

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Related External Products and Publications

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Scientific Integrity Related Policies

The Scientific Integrity Policy, closely following the guidance from Office of Science and Technology Policy (OSTP), includes issues from multiple EPA jurisdictions. In an effort to help EPA employees find the right source of further information, we provide the links below:

EPA has in place clearly articulated policies and procedures protecting against scientific misconduct by all Agency employees, including managers and other Agency leadership, which are summarized in the following document:

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Reporting an Allegation

  • Reporting an Allegation of a Loss of Scientific Integrity

    EPA is dedicated to preserving the integrity of the scientific and scholarly activities it conducts and that are conducted on its behalf. It will not tolerate misconduct or loss of integrity in the performance of scientific and scholarly activities or in the application of science and scholarship in decision making. Scientific and scholarly misconduct and loss of scientific integrity are the result of a deliberate action by an employee that compromises the scientific integrity of the conduct, production or use of scientific and scholarly activities and assessments. Misconduct includes intentional fabrication, falsification or plagiarism and is not the result of honest error or difference of opinion with a scientific and scholarly process or a management decision.

    To report an allegation of the loss of scientific or scholarly integrity, submit it in writing to the Scientific Integrity Official (ScIO), one of the Deputy Scientific Integrity Officials (DScIOs), or the Office of Inspector General. A link to the list of the ScIO and DScIOs and their contact information is below.

    Any matter concerning an allegation of a financial conflict of interest or other ethics issue involving federal employees will be referred to the appropriate Deputy Ethics Official or Office of General Counsel/Ethics, as appropriate.

    Allegations may be submitted by individuals or entities, internal or external to the Agency. An initial notice of an allegation of scientific and scholarly misconduct or loss of integrity reported to the ScIO or DScIO should contain the following information:

    • The name, affiliation and signature of the person(s) submitting the allegation and the name and organization of the person(s) alleged to have committed the misconduct or actions leading to the loss of integrity. If submitted electronically it must be from an email readily linked to the identity of the person submitting.
    • A description of the alleged misconduct or loss of integrity that includes:
      • Date
      • Circumstances
      • Location
    • An explanation of how the allegation relates to scientific and scholarly misconduct or loss of integrity and that demonstrates the impact of the alleged misconduct or loss of integrity.
    • A statement explaining any personal or professional extenuating circumstances, non-scientific disagreements or conflict(s) of interest the person making the allegation has with the subject(s), entity(ies) or situation(s), named in the allegation.
    • A statement indicating if this allegation is being considered or has been submitted elsewhere, such as:
      • Another EPA office
      • Court of law
      • Other jurisdiction
      • Complaint process
      • Governmental office
  • Contacts for Reporting an Allegation

Scientific Integrity Current Projects and Activities

Annual Activities

The Scientific Integrity Policy requires the following annual activities:

  • Scientific Integrity Committee Quarterly Meetings
  • Agency-wide Annual Meeting Webinar
  • Stakeholder Meetings
  • Certification of Compliance with the Scientific Integrity Policy
  • Ongoing Training and Outreach

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Evaluation of the Scientific Integrity Policy

The Scientific Integrity Policy requires that the Scientific Integrity Committee review the Policy every two years to ensure its effectiveness and adherence with applicable rules and regulations. In 2014, the Committee began a formal evaluation of the Policy including a systematic investigation of the merit, worth, and significance of the Agency's efforts to implement the Policy.

The evaluation, which will extend into Fiscal Year 2016, will examine the content, implementation, and impacts of the Policy. It is designed to be a practical, ongoing assessment that involves the Scientific Integrity Committee and other stakeholders. The evaluation process will identify criteria to assess performance, standards that must be reached to consider the program successful, and evidence needed to indicate performance relative to standards. A logic model will synthesize the main program elements into a picture of how the program is supposed to work and make explicit the sequence of events that are presumed to bring about change.

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Authorship Best Practices

The scientific integrity of a final product cannot be assessed without accurate attribution through careful assignment of authorship. The best practices described in this document apply 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.

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Annual Reports, Training, and Outreach Materials

Annual Reports

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Training

In November 2013, OSA issued a training course on the Scientific Integrity Policy. The course is mandatory for all managers and direct-line supervisors and employees within their organizations. All employees are encouraged to take the training. 

The course was designed to familiarize employees with the EPA's Scientific Integrity Policy. All employees, including scientists, managers, and political appointees, are required to follow the Policy when:

  • Engaging in, supervising, managing, or influencing scientific activities
  • Communicating information in an official capacity about Agency scientific activities
  • Utilizing scientific information in making Agency policy and management decisions

In addition, all contractors, grantees, collaborators and student volunteers of the Agency who engage in scientific activities are expected to uphold the standards established by the Policy and may be required to do so as part of their respective agreements with the EPA. 

As other aspects of the policy are fully implemented, additional training will be developed.

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Outreach Materials

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Whistleblower Protections at EPA

When the Whistleblower Protection Enhancement Act of 2012 was signed into law on November 27, 2012, the law bolstered the protections and rights found in the Whistleblower Protection Act of 1989. Among other things, the enhanced Act provides whistleblower protection for government scientists who challenge censorship of scientific information or make whistleblower disclosures related to the integrity of scientific processes. In response to additional requirements of the Act, EPA Office of Inspector General (OIG) has designated a whistleblower protection ombudsman to be responsible for educating employees about whistleblower protections, rights and remedies.

Frequently Asked Questions

  • Frequently Asked Questions
    1. Why is scientific integrity important to the EPA?
      Science is the backbone of the 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 environmental policies, decisions, guidance and regulations that impact the lives of all Americans every day must be grounded, at the most fundamental level, in sound, high quality science.
      When dealing with science, it is the responsibility of every EPA employee to conduct, utilize and communicate science with honesty, integrity and transparency, both within and outside the Agency.
    2. What are the Principles of Scientific Integrity?
      The Agency has long fostered a culture of scientific integrity through its Principles of Scientific Integrity, developed in 1999:
      EPA employees, whatever their grade level, job or duties must:
      • Ensure that the Agency's scientific work is of the highest quality, free from political interference or personal motivations.
      • Represent his/her own work fairly and accurately.
      • Appropriately characterize, convey and acknowledge the intellectual contributions of others.
      • Avoid conflicts of interest and ensure impartiality.
      • Be cognizant of and understand the specific programmatic statutes that guide their work.
      • Welcome differing views and opinions on scientific and technical matters as a legitimate and necessary part of the scientific process.
      • Accept the affirmative responsibility to report any breach of the Scientific Integrity Policy.
      Consistent with these Principles, the Agency's Scientific Integrity Policy reaffirms the expectation that all Agency employees, including scientists, managers and political appointees, regardless of grade level, position or duties, uphold these principles.
    3. What are the roles and responsibilities of the EPA's Scientific Integrity Committee?
      The EPA's Scientific Integrity Committee:
      • Provides leadership for the Agency on scientific integrity.
      • Implements the Scientific Integrity Policy across the Agency in a consistent manner.
      • Promotes Agency compliance with the policy, including safeguarding against and mechanisms to ensure accountability for, any alteration or manipulation of scientific data by managers and other Agency leadership.
      • Addresses Scientific Integrity Policy concerns, updates and amendments.
    4. What does scientific misconduct include?
      Scientific misconduct includes fabrication, falsification, or plagiarism in proposing, performing or reviewing scientific and research activities, or in the publication or reporting of these activities.
      Scientific misconduct does not include honest error or differences of opinion.
    5. What policies and procedures does the EPA have in place to protect against scientific misconduct?
      The EPA has in place clearly articulated policies and procedures protecting against scientific misconduct by all Agency employees, including managers and other Agency leadership, which are summarized in the following document:
  • Frequent Questions about EPA's Scientific Integrity Policy
    1. Why was EPA's Scientific Integrity Policy developed?
      On March 9, 2009, President Obama issued an executive memorandum that articulated the need for sound science to inform and guide agency decisions.
      In response, in 2010, the Office of Science and Technology Policy (OSTP) provided foundational principles and specific expectations for scientific integrity in the Federal government. In particular, OSTP asked the Federal agencies to develop scientific integrity policies that included four areas:
      • Scientific integrity in government
      • Public communications
      • Use of Federal Advisory Committees
      • Professional development of government scientists and engineers
      In February 2012, EPA enacted a new Scientific Integrity Policy that built on the Agency's long history of scientific safeguards and further ensures that sound science drives EPA decision making. The draft policy was open for public comment and the final policy incorporated stakeholder input from:
      • The EPA Science and Technology Policy Council
      • OSTP
      • The public
      • Agency scientists
    2. What are the goals of EPA's Scientific Integrity Policy?
      The goals of the Policy are to:
      • Ensure that the environmental policies, decisions, guidance and regulations that impact the lives of all Americans every day are grounded, at a most fundamental level, in sound, high quality science
      • Enhance the transparency within Agency scientific processes
      • Ensure that scientific research and results are presented openly and with integrity, accuracy and timeliness
      • Ensure the consistent use of peer review and Federal Advisory Committees
      • Promote the professional development of the Agency's scientists, engineers and other technical staff
    3. To whom does EPA's Scientific Integrity Policy apply?
      All employees, including scientists, managers and political appointees, are required to follow the Policy when:
      • Engaging in, supervising, managing or influencing scientific activities
      • Communicating information in an official capacity about Agency scientific activities
      • Utilizing scientific information in making Agency policy and management decisions
      In addition, all contractors, grantees, collaborators and student volunteers of the Agency who engage in scientific activities are expected to uphold the standards established by the Policy and may be required to do so as part of their respective agreements with the EPA.
    4. What is the focus of EPA's Scientific Integrity Policy?
      To promote scientific integrity throughout the Agency, EPA's Scientific Integrity Policy addresses four specific areas:
      • The culture of scientific integrity at the EPA
      • Release of scientific information to the public
      • The use of peer review and Federal Advisory Committees
      • Professional development of government scientists
      In addition, the 2012 policy established the Scientific Integrity Committee, chaired by the Agency's Scientific Integrity Official, to implement the policy

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Programs of the Office of the Science Advisor