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Science Advisor Programs

Allegations of a Loss of Scientific Integrity 2016

EPA had received 106 allegations of a loss of scientific integrity since the Scientific Integrity Policy was published in February 2012 and through September 30, 2016.

The Agency received 22 allegations in fiscal year 2016. This represents a decrease from the 37 that we received in FY2015.

Allegations may be made in two ways:  formally (where the person submitting the allegation is identified) or informally (where the person submitting the allegation prefers to not reveal their identity). Of the 22 allegations that were received in FY2016, twelve were made informally and ten were made formally. For comparison, 55% were informal in FY2016; 81% were informal in FY2015.

Of the twelve informal reports received in FY2016, one came from outside the Agency, seven came from EPA offices and programs, two came from regional offices, and two were anonymous EPA submissions. Of the ten formal allegations in FY2016, three came from outside the Agency, five from EPA offices and programs, and two from regional offices. Of note, there was also a decrease in internal allegations in FY 2016 (18), compared to FY2015 (32).

The allegations received in FY2016 related to several topics regarding scientific integrity. Eight concerned suppression or delay of release of a scientific report or information; seven were interference with science by a manager; one concerned scientific methods; two were scientific misconduct; two were conflicts of interest; one was a differing scientific opinion; and one was about data quality.

While there were eight allegations regarding authorship and attribution in FY2015, there were none in 2016. The elimination of authorship disputes could possibly be due to the release of “Scientific Integrity: Best Practices for Designating Authorship” in 2016, available at https://www.epa.gov/osa/authorship-best-practices.

Summary of Adjudicated Allegations

Eight allegations were adjudicated in FY2016. Four were substantiated, and four dismissed. Three adjudicated allegations concerned authorship disputes; four involved delayed release/suppression of scientific information; and one concerned scientific misconduct. Summaries of the disposition of these allegations are below.

Adjudicated in FY 2016:

          1. Allegation Regarding Authorship Criteria for US EPA Employee Who Made Substantial Contributions to an Article/Abstract of a Non-US EPA Researcher:

An inquiry was received about the criteria for determining if a US EPA employee is entitled to authorship when US EPA work is used in and/or the US EPA employee is asked to comment on an article/abstract developed by a researcher outside of the Agency.

Summary: The Scientific Integrity Official and the Scientific Integrity Committee developed a “Best Practices for Designating Authorship” document to provide a set of objective criteria and general standards to resolve authorship issues. The document is available at https://www.epa.gov/osa/authorship-best-practices. The Scientific Integrity Official shared this document with the inquirer and provided advice.

          2. Allegation Regarding Authorship Criteria for Non-federal Colleague Contributions to US EPA Documents:

An inquiry was received about criteria for authorship for non-federal colleagues that provide technical or scientific advice and substantive input to a US EPA authored document, but not involving a grant or contract.

Summary: The Scientific Integrity Official and the Scientific Integrity Committee developed a “Best Practices for Designating Authorship” document to provide a set of objective criteria and general standards to resolve authorship issues. The document is available at https://www.epa.gov/osa/authorship-best-practices. The Scientific Integrity Official shared this document with the inquirer and provided advice.

          3. Allegation Regarding Authorship Dispute:

A scientist alleged that US EPA scientists were excluded from the authorship list of a journal article and from the abstract/poster for a scientific conference in which they had contributed. In addition, it was alleged that colleagues of the scientist were prohibited from including the scientist as an author on a presentation, to which the scientist contributed, at a professional meeting.

Summary: The Scientific Integrity Review Panel found the allegations to be substantiated and recommended that authorship designation be corrected and that the scientist’s office adopt written clearance procedures consistent with the “Best Practices for Designating Authorship” document, available at https://www.epa.gov/osa/authorship-best-practices.

          4. Allegation of Interference with Science by a Manager:

A scientist accused his/her supervisors of preventing the scientist from working on a topic within the scope of his/her work unit.

Summary: The allegation was dismissed. At US EPA, supervisors may determine what type of work is necessary for employees to fulfill the Agency’s mission.

          5. Allegation of Interference with Science by a Manager:

A scientist accused his/her supervisor of reviewing a portion of a manuscript as harassment. The review was prompted by a colleague who had reported manipulated and/or misrepresented research data or results to management.

Summary: The supervisor initiated an investigation, which found no evidence of manipulated and/or misrepresented research data or results. The scientist and the supervisor resolved the issue, and the allegation was dismissed.

          6. Allegation of Interference with Science by Manager:  

A scientist was denied his/her request to make a division-wide presentation about the scientist’s career at EPA.

Summary: The allegation was dismissed.  The supervisor and employee reached a compromise, and the employee gave a presentation that was not under the auspices of the division.

          7. Allegation of Scientific Misconduct/Laboratory Sabotage:

A researcher at an academic institution with a US EPA assistance agreement was investigating an alleged case of laboratory sabotage and requested information regarding any further US EPA requirements for the investigation in addition to fulfilling their institutional requirements.

Summary: The researcher was directed to Federal Policy on Research Misconduct (EPA Order 3120.5), which specifies procedures for addressing research misconduct for all federally funded and federally conducted research.

          8. Allegation that the EPA Media Policy Restricts Media Access to US EPA Scientists:

A US EPA employee spoke to media without indicating that he/she was speaking in a personal capacity and not as a US EPA employee. Management issued a suspension for failing to notify them prior to the employee speaking with the media. The employee alleged a scientific integrity violation for suppressing information.

Summary: The allegation was dismissed. The failure to notify the employee’s management was not found to be a scientific integrity issue.

Additional Allegations Adjudicated in FY2015:

          1. Allegation of Interference with Science by a Manager:

US EPA scientists asked a manager to request relevant studies from a manufacturer for a risk assessment. Management blocked the request and reassigned the staff.

Summary:  The office asked for and received the studies five years later and incorporated the information into the risk assessment. The Scientific Integrity Official also provided training for the office on scientific integrity. The allegation was substantiated.

          2. Allegation of Self-Plagiarism:

A manager asked to review a document in which it was alleged an employee had self-plagiarized.

Summary: This allegation was substantiated. The employee was counseled. Self-plagiarism is addressed in “Best Practices for Designating Authorship” available at https://www.epa.gov/osa/authorship-best-practices.

          3. Concern Regarding the Lack of a Systematic Review Process for IRIS:

A chemical trade association expressed concern about the lack of a systematic review process for available studies by the IRIS program.

Summary: The allegation was not found to be a scientific integrity issue but rather a difference in scientific judgement. The IRIS program has implemented a process for systematic review in its assessments, in accordance with recommendations by the National Research Council.

Additional Allegations Adjudicated in FY2014:

          1. Concern about a Loss of Scientific Integrity Due to Staff Reductions:

A scientist expressed concern that staff reductions were leading to a loss of scientific integrity. 

Summary: The reorganization of the subject office addressed the issue.

          2. Allegation Regarding Suppression of Scientific Report:

An employee expressed a concern that a request from an Agency counselor that a journal article submission be delayed during rule-making negotiations was a suppression of science and a violation of scientific integrity.

Summary:  The allegation was substantiated. The journal article has been published.

          3. Allegation regarding US EPA Policy on FAC Members’ Ability to Speak with the Media and Public:

Several NGOs sent a letter to the US EPA Administrator to express their concern that a recent memorandum regarding the policy on communication between members of FACs and parties outside of EPA is a violation of the Agency’s Scientific Integrity Policy.

The FACA communication policy can be found at: https://yosemite.epa.gov/sab/sabproduct.nsf/webfiles/policy-communication/$file/policy-gkf-04.11.14.pdf.

Summary: A clarification to the policy was issued that states that the EPA policy only applies to FAC members regarding the work for which they were appointed to do. The clarification to the policy can be found at: https://yosemite.epa.gov/Sab/Sabproduct.nsf/WebFiles/2014Clarification/$File/ClarPol-11-2015-2.pdf.