Scientific Integrity and Misconduct Issues

Scientific Integrity at the EPA 

Scientific integrity at the EPA helps ensure that the development and use of science in the Agency’s decision-making is of the highest quality. 

“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 a most fundamental level, in sound, high quality science.” 

—The EPA’s 2012 Scientific Integrity Policy, section II

As part of its agencywide strategy of ensuring scientific integrity and reinforcing science as foundational to EPA decision-making, the FY2022-2026 EPA Strategic Plan calls for adhering to scientific and ethical standards and supporting robust discussion of different scientific points of view. 

Scientific Integrity Policy

The EPA issued its first Scientific Integrity Policy in February 2012. The policy conveys the expectation that all EPA employees, contractors, and grantees will adhere to the terms of the policy, including reporting policy breaches. 

In early 2021, the EPA began updating its 2012 Scientific Integrity Policy in response to the Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking. As shown below, the OIG provided two rounds of formal comments on the draft policy. The revised Scientific Integrity Policy was released on January 16, 2025. While the Agency incorporated some of our suggestions into the policy, it did not resolve issues concerning the OIG’s role in protecting scientific integrity, as well as Agency employees’ responsibilities for reporting their concerns to the OIG. The 2025 Scientific Integrity Policy also did not make explicit reference to the disclosure of censorship relating to scientific research or analysis as a protected activity under the Whistleblower Protection Enhancement Act of 2012.

• OIG General Comments to Preliminary Draft of Scientific Integrity Policy (pdf) (196.36 KB) , issued November 17, 2022. 
• OIG Comments to Revised Draft of Scientific Integrity Policy (pdf) (305.7 KB) , issued April 11, 2024.

In August 2025, in response to the May 23, 2025 executive order titled “Restoring Gold Standard Science,” the EPA rescinded its 2025 Scientific Integrity Policy and reinstated its 2012 policy. 

Whistleblower Protections for EPA Employees and Scientists

As outlined on the OIG’s Whistleblower Protection webpage, the Whistleblower Protection Act grants covered federal employees the right to make whistleblower disclosures and protects those employees from retaliation for making covered disclosures. Regarding scientific activities, the law includes protections covering censorship, which is defined as “any effort to distort, misrepresent, or suppress research, analysis, or technical information.” 

Specifically, EPA employees are protected from retaliation for making disclosures about censorship related to research, analysis, or technical information if the employee has a reasonable belief that the censorship would constitute or cause a violation of law, rule, or regulation; gross mismanagement; a gross waste of funds; an abuse of authority; or a substantial and specific danger to public health or safety. 

Additionally, the EPA’s 2012 Scientific Integrity Policy extends the protections of the Whistleblower Protection Act to all EPA employees who uncover or report allegations of scientific and research misconduct or who express a differing scientific opinion.  

The OIG’s Role in Scientific Integrity at the EPA 

The OIG has a critical role in protecting the Agency’s adherence to scientific integrity. As an independent office, the OIG can receive complaints of mismanagement, misconduct, abuse of authority, or censorship, including those related to scientific or research misconduct, without fear of improper influence. And, through its statutory mandate, the OIG can investigate these allegations. Unlike the Agency’s scientific integrity program, the OIG can grant confidentiality protections to complainants under the Inspector General Act of 1978, as amended.  

Whistleblowers can assist the OIG in identifying any potential systemic scientific integrity issues. The OIG can then initiate audits or evaluations that result in recommendations to correct the root causes of these issues. 

Scientific or Research Misconduct Allegations 

Under the EPA’s 2012 Scientific Integrity Policy, “[S]cientific misconduct includes the 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. Scientific misconduct is normally adjudicated by the Office of Inspector General.” 

Research misconduct is the fabrication, falsification, or plagiarism in proposing, performing, or reviewing research or in reporting research results; or ordering, advising, or suggesting that subordinates engage in these activities. Examples of misconduct include manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record. 

EPA Order 3120.5 contains the Agency’s policy and procedures for addressing research misconduct, including the requirement for EPA employees to immediately notify the OIG via the OIG Hotline of any allegation that involves any of the following: 

• Risk to public health or safety.
• Threats to Agency resources or interests.
• Circumstances in which research activities should be suspended.
• A reasonable indication of possible violations of civil or criminal law.
• Instances in which federal action is required to protect the interests of those involved in the investigation.
• Situations in which the research entity believes that the inquiry or investigation may be made public prematurely so that appropriate steps can be taken to safeguard evidence and protect the rights of those involved.
• Circumstances in which the research community or public should be informed. 

Additionally, supervisors, employees, and assistance recipients are responsible for promptly reporting allegations of wrongdoing or irregularities, including those involving scientific misconduct, to the OIG. Furthermore, anyone who becomes aware of alleged research misconduct from or by research institutions—such as assistance agreement recipients and contractors or their employees—should promptly report allegations to the OIG, even if an external entity conducts its own inquiry. 

The OIG will not disclose the identity of any employee reporting allegations of scientific or research misconduct, including allegations of censorship, unless the employee consents to disclosure or the inspector general determines that such disclosure is unavoidable during an investigation.

OIG Coordination with the EPA 

The EPA’s 2012 Scientific Integrity Policy directs the EPA’s scientific integrity official to coordinate with the OIG on issues of scientific misconduct. As part of this coordination, the SIO is required to report research misconduct allegations to the OIG within seven days of receiving the allegation, and the OIG will report an allegation within seven days to the SIO, as appropriate. 

Scientific integrity program staff and OIG staff meet every three weeks to discuss the status of cases, as appropriate, as well as other scientific integrity-related issues. Since 2021, the OIG has been in discussions with the Agency to revise coordination procedures related to information sharing on scientific integrity, but updated procedures have yet to be finalized. Revised procedures are essential to the Agency’s scientific integrity reforms, as they will ensure that concerns are routed to the proper office and addressed efficiently and effectively. 

Examples of OIG Scientific Integrity-Related Reports