and judicial deadlines might make it necessary that a program-office decision-maker retain the authority to proceed with an action on a provisional basis despite objections or concerns 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 the criticism is clearly noted, divulged, and explained.

The committee also recommends that the Science Policy Council's reviews of the agency's peer-review handbook and of experiences with its implementation include an explicit focus on promoting appropriate forms and levels of review for different types of work products and on reducing unnecessarily complex or inefficient requirements. The Science Policy Council should not necessarily wait the 5-year interval specified in the peer-review handbook; it should make changes as needed. The agency cannot afford to allow unnecessary or inefficient requirements to continue so long. The Science Policy Council's review should be ongoing. We also recommend that the Science Policy Council review a true random sample of peer-reviewed work products, examining the decisions made in structuring the review, the responses to review, and the cost, quality, timeliness, and impact of the review.

Finally, the committee wishes to emphasize that peer review must become accepted throughout EPA as a part of the agency's culture – a tool for improving quality – not merely a bureaucratic requirement. Measures such as periodic dissemination of the impacts and benefits of completed reviews might help to foster this cultural change in the agency.

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