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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices
and subordinate managers in the agency's regulatory programs accountable for peer review. Nevertheless, independence is essential to the proper functioning of the peer-review process, and EPA's current policies fail to ensure adequate independence. Our committee shares the SAB's concern about the potential conflicts of interest of EPA peer-review leaders and decision-makers.
Therefore, our committee recommends that EPA change its peer-review practices to more strictly separate the management of a work product from the management of the peer review of that work product. The committee believes that the decision-maker and peer-review leader for a work product should never be the same person, and that wherever practicable, the peer-review leader should not report to the same organizational unit as the decision-maker. Although the decision-maker should retain the authority to overrule provisionally any decisions or objections from a peer-review leader, with the final decision to be made by the EPA administrator, 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. If such an independent assessment produces criticism of the adequacy or outcome of a peer review, EPA's policy should be to ensure that such criticism is clearly noted, divulged, and explained.
For completed research work products, our committee encourages ORD to continue and to expand its longstanding practice of urging the in-house and extramural research scientists it supports to publish their research in peer-reviewed journals that meet international standards of scientific quality. To the extent possible, intramural and extramural research supported by EPA should be published in peer-reviewed journals that are open to scientific and public scrutiny. When such publication is not possible (e.g., when the volume of the research results that are important to the agency is so large that the pertinent results cannot be accommodated in a peer-reviewed journal), panels of experts should make an evaluation of quality that is essentially equivalent to that of the peer-reviewed scientific literature. Evaluations should include scientists and engineers from outside ORD and also outside EPA.