July 17, 2021 Liz Borkowski, MPH 0Comment

During his first week in office, President Biden signed the presidential memorandum on “Restoring Trust in Government through Scientific Integrity and Evidence-Based Policymaking,” which establishes a process for strengthening the scientific integrity policies that President Obama instructed federal agencies to create. Biden’s memorandum instructs the White House Office of Science and Technology Policy (OSTP) to convene an interagency task force to review the effectiveness of existing scientific integrity policies. The task force then has to develop a framework to inform and support assessment and improvement of scientific integrity policies and practices; using that framework, agencies will update or create scientific integrity policies and submit them to the OSTP director.

The White House announced the launch of its 46-member Scientific Integrity Task Force in May, and published a complete list of its members in June. The news release that lists the task force members also describes their recent work:

During its most recent meetings, the Task Force established working groups to examine instances in which scientific integrity policies were not followed or enforced and identify effective practices for ensuring integrity in emerging areas of scientific and technological research and analysis, improving training in scientific integrity, bolstering research transparency, and protecting science communication. In addition, given the importance of scientific integrity as a foundation for trust in government, the Task Force formed a working group to coordinate external engagement—to gather feedback from a range of stakeholders, including the American public, through a range of interactions and channels for input, including upcoming listening sessions and the RFI announced today.

On June 28, the Federal Register contained a “Request for Information to Improve Federal Scientific Integrity Policies” from OSTP. It requests input on the following:

(1) The effectiveness of Federal scientific integrity policies and needed areas of improvement;

(2) good practices Federal agencies could adopt to improve scientific integrity, including in the communication of scientific information, addressing emerging technologies and evolving scientific practices, supporting professional development of Federal scientists, and promoting transparency in the implementation of agency scientific integrity policies; and

(3) other topics or concerns that Federal scientific integrity policies should address.

“We need all of America to help protect scientific integrity and restore public trust,” said OSTP Deputy Director for Science and Society Alondra Nelson in the news release that announced the RFI.

Comments are due at 5pm ET on July 28, 2021. The 30-day window doesn’t give stakeholders a whole lot of time to compile comments, but it’s in keeping with the ambitious timeline that Biden’s memorandum sets forth. That schedule gives OSTP just 120 days to conduct a review of existing scientific integrity policies, and another 120 days to develop the framework that will inform agencies’ revision or creation of policies—something they’ll have 180 days to complete.

OSTP will also be holding three public listening sessions: July 28 on communications, July 29 on science and education, and July 30 on use of scientific and technical information. Anyone who wants to participate must register by 5pm ET on July 23.

The Union of Concerned Scientists has posted a comment guide with advice for submitting a strong comment and several specific suggestions that their organization endorses. Another relevant resource is the model scientific integrity policy that Climate Science Legal Defense Fund published last year. And as I draft comments from my organization, the Jacobs Institute of Women’s Health, I’ll also be looking back at the recommendations that we and many other organizations published prior to the 2020 election: Restoring Science, Protecting the Public: 43 Steps for the Next Presidential Term and Restoring Science, Protecting the Public: Recommendations for Federal Agencies in the Next Presidential Term.

One of the things I’ll be thinking about while drafting comments is the way that scientific integrity policies established in the Obama years failed to prevent a horror show of attacks on science during the Trump administration—as well as problems at CDC and FDA under Biden. Policies that prohibit interfering with science but lack mechanisms for holding wrongdoers accountable are part of the problem. Sharon Lerner wrote for The Intercept about how EPA is investigating a host of scientific integrity complaints, and in several cases reversing Trump administration actions—but “agency officials have not named or held accountable the people responsible for interference with [a problematic PFAS toxicity] assessment or any of the other breaches of scientific integrity it has already identified.” If people who want to interfere with science don’t face consequences when they attempt it, they’re likely to keep doing it. In order for scientific integrity policies to be effective, they must contain processes that allow employees and contractors to report abuses—in a process that they can reasonably expect will result in a just outcome and not retaliation—and officials to investigate and punish those found to have violated the policy.

The deadline for submitting comments on scientific integrity policies (5pm ET on July 28) is approaching quickly. If you have recommendations, check out the RFI for instructions and let OSTP know what you think.

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