Strengthening Science at the U.S. Environmental Protection Agency Research-Management and Peer-Review Practices (2000) / Chapter Skim
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Executive Summary
Executive Summary
Pages 1-22
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have primary missions to advance scientific and technical knowledge through research. Yet, EPA's strategic plan strongly acknowledges that environmental protection efforts need to be "based on the best available scientific information," and "sound science" is one of the agency's avowed major goals.
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To carry out the study, the NRC appointed the Committee on Research and Peer Review in EPA, which prepared an interim report addressing the initial request from Congress, and this, the final report in the study. Also as part of the study, the NRC appointed the Comm~ttee on Research Opportunities and Priorities for EPA, which prepared an interim report and the 1997 report Building a Foundation for Sound Environmental Decisions.
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In addition, smaller teams of committee members and staff made site visits to 12 EPA laboratory facilities across the country, in addition to all EPA regulatory offices and 5 of EPA's 10 regional offices. At these locations, committee members and staff interviewed a cross section of EPA personnel, including senior officials, middle managers, staff scientists and eng~neers, and support staff.
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of academicians, including two members of our committee, concluded, "Currently, EPA science is of uneven quality, and the Agency's policies and regulations are frequently perceived as lacking a strong scientific foundation." While acknowledging that EPA had a number of knowledgeable scientists on its staff, the panel reported that the science base at EPA was not perceived" to be strong by the university community, and that many EPA scientists at ah levels throughout the agency believed that EPA did not use their scientific knowledge and resources effectively. The pane} further observed, "A perception exists that regulations based on unsound science have led to unneeded economic and social burdens, and that unsound science has sometimes led to decisions that expose people and ecosystems to avoidable risks." The pane!
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The heads of EPA's regulatory and regional offices are of equal rank to the head of ORD and are generally not required to follow ORD's guidance regarding scientific activities or science policy. Third, the ability of the head of ORD to coordinate agency-wide peer-review and quality-assurance practices was diminished in 1999 with the reassignment of some peer-review functions from ORD to the agency's newly created Office of Environmental information.
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Moreover, assigning agency-wide scientific authority to the assistant administrator for ORD might produce a conflict of responsibilities, because many decisions about science in the regulatory programs could affect ORD's budget or favor ORD's research over research done elsewhere. EPA needs an appropriately qualified science official at a sufficiently high level to carry both the authority and the responsibility for agencywide scientific performance.
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The current position of deputy administrator could perhaps become deputy administrator for policy and management. The new deputy administrator for science and technology would be responsible for identifying and defining the important scientific issues facing EPA, including those embedded in major policy or regulatory proposals; developing and overseeing an integrated agency-wide strategy for acquiring, disseminating, and applying scientific information; coordinating and overseeing scientific quality-assurance and peer-review practices throughout the agency; developing processes to ensure that appropriate scientific information is used in decision-making throughout the agency, and ensuring that the scientific and technical information underlying each EPA regulatory decision is valid, appropriately characterized in terms of scientific uncertainty and cross-media issues, and appropriately applied.
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Seek ways to give research managers in ORD a high degree of flexibility and commensurate accountability. Empower and charge them to make research program decisions at the lowest appropriate management level consistent with EPA policy and ORD's strategic goals and budget priorities.
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ORD responded to the 1992 recommendation by obtaining and using special authority to recruit and promote research scientists and eng~neers to senior, nonmanagerial federal career positions—so-called ST (scientific and technical) positions at the Senior Executive Service level.
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These individuals should be given maximum intellectual freedom to pursue productive lines of research that are consistent with laboratory missions and ORD priorities. The distinguished investigators should be expected to serve as mentors and role models for other ORD research scientists but should have no managerial responsibility beyond their own on-site research teams.
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EPA's ORD conducts research in its in-house laboratories, funds extramural research at academic institutions and other organizations, performs a variety of activities in the development and application of risk-assessment methods and regulatory criteria, and provides technical services in support of the mission of the agency and its regulatory and regional offices. In fiscal year 1999, ORD had 1,976 staff members at 12 geographically dispersed laboratory facilities, three field stations, three assessment offices, and the headquarters office in Washington, DC.
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The plans are developed by research teams from ORD laboratories and centers and are peer reviewed. Our committee expects that ORD's recent efforts in multiyear planning will contribute to research program continuity and the achievement of strategic goals, and the committee commends ORD for these initiatives.
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ORD's technical assistance provides the regulatory offices with competent scientific help and leadership, and it enables ORD's research scientists to keep abreast of regulatory and policy developments elsewhere in EPA. In the 1997 NRC report Building a Foundation for Sound Environmental Decisions, our companion committee in this study concluded that ORD should maintain a balance between the problem-driven research and technical support for the agency's regulatory programs and the core research to better understand and anticipate environmental risks.
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in the 1992 report Safeguarding the Future: Credible Science, Credible Decisions, a pane! of four senior academicians, including two members of our committee, concluded that EPA needs its own strong science base to provide the background required for effective environmental protection programs.
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The committee encourages strengthening the interactions between STAR grantees and research scientists and engineers in the ORD laboratories. At present, there are insufficient mechanisms for facilitating such interactions effectively.
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Recently, the GAO reported that one of EPA's regulatory program offices so acutely needed information on ORD's work—information relevant to its program and well beyond the progress reports that ORD was providing—that the regulatory office found it necessary to pay for the development of a system to track ORD's projects. That kind of situation is not healthful for ORD or the agency.
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Although the ORD strategic plan discusses the general processes and criteria by which decisions are made on research priorities and funding allocations, the plan describes the processes and criteria only in very broad terms. During the committee's site visits and interviews, the staff of some EPA regulatory program offices expressed the belief that they have little influence on ORD's research priorities through the Research Coordination Council or any other mechanism.
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agency-wide science inventory by conducting, documenting, and publishing a more comprehensive and detailed inventory of all scientific activities that are being conducted by offices throughout EPA. ORD's research should not be the only scientific studies held accountable in EPA.
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Our committee commends the agency for this important step. We recommend that the administrator direct the new deputy administrator for science and technology to expand on the preliminary-inventory by documenting a more comprehensive and detailed inventory of scientific activities conducted by all EPA offices.
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The committee recognizes that statutory and judicial deadlines can make it necessary that a program-office decision-maker retains the authority to proceed with an action on a provisional basis in the face of concerns or objections from a peer-review leader, the final decision being made by the EPA administrator. However, the independent decisions and any objections of a peer-review leader should be preserved and made a part of the agency decision package and public record for a work product.
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We also recommend that the Science Policy Counci! review a true random sample of peer-reviewed work products, exam3~ung the decisions made in structuring the review, the responses to review, and the cost, quality, timeliness, and impact of the review.
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In Safeguarding the Future: Crec/ib/e Science, Creclib/e Decisions (EPA 1992) , a pane' of senior academicians, including two members of this NRC committee, concluded, "Currently, EPA science is of uneven quality, and the Agency's policies and regulations are frequently perceived as lacking a strong scientific foundation." While acknowledging that EPA had a number of knowledgeable scientists on its staff, the pane!
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