• research partnerships and outreach;

  • research accountability; and

  • scientific peer review.


In the 30 years since EPA was created, the agency's scientific practices and performance have been criticized many times in reports from the NRC, EPA's SAB, the General Accounting Office, and many other organizations; in congressional oversight and judicial proceedings; and in countless criticisms and lawsuits from stakeholders with interests in particular EPA regulatory decisions. In one such report, Safeguarding the Future: Credible Science, Credible Decisions (EPA 1992), a panel 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 all levels throughout the agency believed that EPA did not use their scientific knowledge and resources effectively. The panel 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 panel commented that EPA had not always ensured that contrasting, reputable scientific views were well-explored and well-documented from the beginning to the end of the regulatory process. It pointed out that the agency was often perceived to have a conflict of interest because it needed science to support its regulatory activities, and it described a widely held perception by people both outside and inside the agency, that EPA science was “adjusted” by EPA scientists or decision-makers, consciously or unconsciously, to fit policy.

As discussed in many places throughout this report, EPA has made significant improvements in some of its scientific practices since that panel issued its report in 1992. However, the committee concludes that there is a continuing basis for many of the scientific concerns raised in

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