Strengthening Science at the U.S. Environmental Protection Agency Research-Management and Peer-Review Practices (2000) / Chapter Skim
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Strengthening Science at EPA
Strengthening Science at EPA
Pages 125-146
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From page 125... ...
Members of our committee made many site visits to EPA's laboratories, centers, and headquarters and regional program offices, as listed in the first chapter of this report. In addition, several members of our comm~ttee have gained considerable knowledge of EPA research-management and peer-review practices through participation in previous and ongoing reviews of various scientific activities in EPA under the auspices of the NRC, the SAD, the BOSC, and other organizations.
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From page 126... ...
SCIENTIFIC LEADERSHIP AND TALENT 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 SAD, 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)
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From page 127... ...
The pane! recommended that the new science advisor advise the EPA administrator, implement a peerreview and quality-assurance program for all EPA science-basea proaucts; be a key player when EPA makes a policy decision, ensuring that the science and uncertainties relevant to a policy or regulatory issue are considered; play a key role in evaluating the professional activities of EPA scientists; reach out to the broader scientific community for information; and maintain an appropriate relationship with EPA's SAB.
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From page 128... ...
The agency's most senior science official has traditionally been the assistant administrator for research and development, but that official has never had agencywide responsibility or authority for overseeing the scientific and technical basis for regulatory and policy decision-making, and EPA's regulatory offices are not required to follow scientific advice from ORD. That is a formula for weak scientific performance in the agency and poor scientific credibility outside the agency.
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From page 129... ...
Based on many of the issues discussed in this report and the extensive experience of the members of our committee with scientific practices in EPA, the committee concludes that EPA needs an appropriately qualified scientific official at a sufficiently high level to carry both the authority and responsibility for agency-wide scientific performance. No official below the level of deputy administrator could perform this role.
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From page 130... ...
is relied upon by the administrator to determine whether a proposed action is "legal," an appropriately qualified and adequately empowered scientific official is needed to attest to the administrator and the nation that the proposed action is "scientific"—that it is consistent, or at least not inconsistent, with available scientific knowledge and that the agency has done a proper job of ascertaining and applying that knowledge and recognizing and characteriz~ng the relevant uncertainties. Achieving these goals will require a level of accountability for EPA's scientific performance that cannot reasonably be expected from an administrator who is not trained In science, a staff advisor to the administrator without line authority, or an assistant administrator for research and development who has no authority over the use of scientific information by other offices of the agency.
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From page 131... ...
(EPA 1992~. This official would coordinate and oversee the agency's Office of Research and Development, the newly-created Office of Environmental information, Science Advisory Board, Science Policy Council, and scientific and technical activities in the agency's regulatory program and regional offices.
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From page 132... ...
However, although the political aspect of the assistant adm~nistrator's job often receives considerable attention, the most important aspects of the job are not political. Besides running ORD, the assistant administrator is responsible for representing EPA's research program to the worId's scientific community, interpreting the agency's research and development program to the public, and maintaining a national and international watch on major environmental science and engineering developments.
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From page 133... ...
Excessively bureaucratic procedures are antithetical to a creative research program with a high standard of quality, efficiency, and teamwork. ORD should frequently examine itself to identify and eliminate excessive bureaucratic safeguards, administrative hurdles, redundant requirements for approvals at multiple levels of management, and other bureaucratic impediments.
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From page 134... ...
The committee commends ORD for the excellent fellowships program it has developed. This program has brought a stream of fresh scientific and technical talent into EPA's research program and is helping to train future research leaders in environmental science, engineering, and other disciplines.
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From page 135... ...
However, recognizing today's intense jobmarket competition with industry and academic institutions for top research talent, the committee concludes that even greater measures are warranted and practicable to attract and retain outstanding research scientists and engineers in the ORD laboratories. In research, perhaps even more than in other fields, pre-em~nent leadership sets the standard and tone for the rest of the work force.
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From page 136... ...
RESEARCH CONTINUITY AND BALANCE Frequent changes in goals, priorities, practices, structure, or funding can disrupt any organization, but they are especially damaging to a research organization, which has special requirements for continuity In the development and maintenance of scientific and engineering talent, experience, and infrastructure if it is to be productive. Maintaining the requisite degree of stability in ORD has been a continuing challenge due to many expansions and other changes in EPA's legislative mandates and priorities, directives from Congress and different administrations, pressures from regulated parties and other interest groups, lawsuits and court decisions, inadequate budgets to meet competing demands, and changes in the leadership of ORD and EPA.
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From page 137... ...
Our committee expects that ORD's recent efforts in multiyear planning will contribute greatly to research program continuity and the achievement of strategic goals, and ORD merits commendation for these initiatives. The committee recommends that ORD continue and expand its multiyear research planning approaches in both problem-driven and core research areas.
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From page 138... ...
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
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From page 139... ...
An EPA devoid of a research program would not be likely to attract substantial scientific talent, and an EPA without scientific talent would be ineffective and potentially harmful to the nation. However, even with a much larger budget, ORD could not meet all the vast and constantly expanding needs of EPA and the nation for scientific and technical knowledge to guide environmental protection efforts.
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From page 140... ...
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.
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From page 141... ...
Recently, the GAO reported that one of EPA's regulatory program offices so acutely needed information on ORD's work (relevant to its program) , 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 (GAO 1999~.
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From page 142... ...
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. They felt that they needed a stronger voice in the sewing of ORD's priorities, and that ORD should be held more accountable to the agency's other offices for performing agreed-upon tasks.
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From page 143... ...
ORD should continue to be responsive to the agency's regulatory offices for the problem-driven and technical-assistance components of its program, and the agency's regulatory offices should continue to have a strong voice in decisions about the ORD plans and budget elements devoted to those components. For the core-research portion of its program, however, ORD should have greater freedom to set the agenda, without the need for specific concurrence of regulatory program offices that are focused on statutory requirements and regulatory goals.
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From page 144... ...
The committee recommends that the administrator direct the deputy administrator for science and technology to expand upon the agency's recently initiated science inventory by conducting, documenting, and publishing a more comprehensive and detaiZedt inventory of al' scientific activities conducted by agency units outside ORD. The results of the inventory should be used to ensure that such activities are properly coordinated through the agency-wide science-planning and budgeting process anal are appropriately peer reviewed.
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From page 145... ...
The committee recommends that EPA change its peer-review policy to more strictly separate the management of the development of a work product from the management of the peer review of that work product, thereby ensuring greater independence of peer reviews from the control of program managers, or the potential appearance of contro' by program managers, throughout the agency. 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.
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From page 146... ...
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.
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