Approaches for Expressing and Resolving Differing Scientific Opinions
EPA expects and encourages all employees to offer and welcome differing scientific opinion A differing opinion of an EPA scientist who is or was substantively engaged in the scientific activity that may inform an EPA decision. It generally contrasts with a prevailing staff opinion included in a scientific product under development that concerns scientific data, environmental information, analysis, interpretations, or conclusions, rather than policy options or decisions. "Substantively engaged in the science" refers to having contributed scientific expertise in an official capacity as a co-author, team member, or subject matter expert in the development of a scientific product, beyond presence at meetings or on mailing lists. If a scientist serves as a technical or peer reviewer, their scientific opinions should be included as part of the review consistent with EPA’s Peer Review Handbook. Scientific differences of opinion do not constitute insubordination or research misconduct and are part of the scientific process. A differing scientific opinion does not include personal opinions about scientific issues that are not accompanied by scientific arguments. [EPA 2025 Scientific Integrity Policy]s as a legitimate and necessary part of the scientific process.
Scientific products Work products that contain scientific information. These include, but are not limited to, journal publications, reports, abstracts, posters, presentations, audio recordings, videos, web content, risk assessments, technical studies and guidance, analytic methods, scientific database designs, technical tools and models, technical protocols, statistical surveys/studies, technical background materials, technical guidance, research plans, and research strategies. They can support a research agenda, regulatory program, policy position, or other EPA position or action. [EPA 2025 Scientific Integrity Policy] and decisions are strengthened by considering all pertinent evidence and exploring various plausible explanations of that evidence. Vigorous internal discussion of different points of view helps to anticipate counter-arguments and alternative positions that could arise during public comment, peer review A documented process for enhancing a scientific or technical work product so that the decision or position taken by the agency, based on that product, has a sound, credible basis. It is performed by credible individuals who are independent of those who performed the work and who are at least collectively equivalent in technical expertise to those who performed the original work. [EPA 2025 Scientific Integrity Policy], and litigation. This process of challenging and improving ideas helps to guard against inadequate science and flawed analyses. The Differing Scientific Opinions document recommends a progression of approaches that employees and managers can use to encourage the expression and satisfactory resolution of differing scientific opinions.
EPA’s Scientific Integrity Policy states that the policy “extends whistleblower protections to all EPA employees who uncover or report allegation An accusation of a suspected loss of scientific integrity or violation of the EPA's Scientific Integrity Policy that is specifically designated as an allegation by the submitter. [EPA 2025 Scientific Integrity Policy]s of scientific and research misconduct Fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results; or ordering, advising, or suggesting that subordinates engage in research misconduct. Research misconduct does not include honest error or differences of opinion. [EPA 2025 Scientific Integrity Policy], or who express a differing scientific opinion, from retaliation or other punitive actions."