Principles of Workgroup Participation for Document Review

EPA established the Technical Support Project (TSP) in 1987 to provide technical assistance to Regional Remedial Project Managers, Corrective Action Staff, and On-Scene Coordinators. The Project consists of a network of regional forums and specialized technical support centers located EPA laboratories, and EPA's Environmental Response Team. The objectives of the TSP are to share information and best practices with other EPA programs and other Federal agencies. For more information on the TSP, please visit Technical Support Project page. The following list contains the expectations of workgroup members conducting document reviews as part of the TSP as adopted July 2005:

1. Document Review workgroup participation will be established as outlined in Section II, Part B of the October 15, 1998, TSP Ground Water Forum Organizational Procedures (a.k.a. “By Laws”).

2. Differences of opinion within a workgroup will be resolved to the greatest extent possible before the close of any workgroup conference call or other communication. It is the responsibility of the workgroup chair to assure that differences of opinion within the workgroup are resolved to the greatest extent possible within a reasonable time period.

3. It is the responsibility of workgroup members to keep an open mind and to respect the ideas of their colleagues. All viewpoints will be given full consideration before any decisions are made. A workgroup member is agreeing to be part of a team and should not act independently on the issue being reviewed without the prior approval of the workgroup. It is the workgroup member’s responsibility to facilitate the completion of the workgroup’s task.

4. Workgroup participants will avoid any conflicts of interest or apparent conflicts ofinterest in order to assure impartiality. Some conflicts of interest are generally described in the EPA Peer Review Handbook (2nd Edition, 2000; EPA 100-B-00-001). It is the responsibility of the individual prospective or active workgroup participant to determine if he/she has any conflicts of interest or apparent conflicts of interest that would influence the review and take appropriate action with regard to any participation in the workgroup. It is the responsibility of the workgroup to evaluate and respond to any workgroup participant’s perceived conflict of interest.

5. Workgroup review and comment will be timely. Workgroup members have a responsibility to meet this commitment and submit comments by the established deadlines. Participants who have concerns about meeting agreed upon deadlines will notify the workgroup chair in a timely manner of their likely inability to meet any due dates. The workgroup chair must establish deadlines and communicate those deadlines to workgroup participants in a timely manner.

6. Workgroup participants should avoid any communication with document authors and non-workgroup parties regarding internal workgroup deliberations. If a workgroup participant wishes to communicate with document authors or persons outside of the workgroup regarding internal workgroup deliberations, that person should do so only after concurrence of the workgroup and with the participation the workgroup chair. That communication should be reported back to the workgroup.

7. Comments provided by workgroup participants will include (as appropriate) any references for sources of information, will provide sufficient explanation for the comments, and will adhere to any constraints placed upon the time, length andscope of requested comments.

8. The review process should be transparent. Sufficient records should be maintained to document the review process and substantiate the workgroup’s decisions and consolidated review comments.

9. A review workgroup member is a professional who brings his/her knowledge and experience to the workgroup deliberations, but his/her opinion does not represent an agency policy. The internal deliberations of the workgroup do not represent the position of the participating agencies (U.S. EPA or any state environmental agency). Once the workgroup’s work product (i.e. consolidated review comments) is adopted by the whole Ground Water Forum, the work product then solely represents the Ground Water Forum.