The White House Office of Science and Technology Policy (OSTP) held three listening sessions at the end of last month on Scientific Integrity and Evidence-Based Policymaking. These are key issues for the Center for Science and Democracy (CSD) at UCS that we have been working on for more than 15 years, since the George W. Bush Administration. So, we wanted to take advantage of the opportunity. Four of my colleagues in CSD and I stepped up to each provide testimony in the two minutes allowed for each speaker. I hope you will agree we packed a lot into a short time! (Note: I have done some slight paraphrasing below for readability and length)
I was first up in the first session on communication. In my two minutes I told OSTP, “Agencies should not be scared of scientists speaking up! Scientists should be encouraged (not just allowed) to communicate directly to the public, including on social media.
“The weight of evidence must be the basis for decisions. But what is included in that evidence? Federal scientists need to think more broadly and not be trapped into only considering designed experiments or surveys. Community members are experts in their own right and their lived experiences are critical data. To confront problems of equity and justice, community data must be given full weight and openly communicated by agencies.
“The Union of Concerned Scientists and many other national and grassroots organizations have made recommendations for many years on trust building, scientific integrity and science communication. There is a great degree of alignment in recommended changes to better serve the public interest in policy decisions, rather than political or industry interests. OSTP should use civil society recommendations to guide all agencies to implement not only scientific integrity policies, but better communication, transparency and science-based decision making practices that are just, equitable, and responsive to public interests.”
Equity for communities
My colleague Anita Desikan, in her testimony during the session on the importance of community-scientist partnerships said, “For over 40 years, environmental justice research has shown that underserved communities face enormous health burdens from exposure to pollution, toxic chemicals, and other environmental stressors. Heavily impacted, underserved communities are often marginalized in both federal scientific work and public policies. When community level impacts are not fully incorporated into scientific analyses, the result is a continuation of inequity and injustice.
“Therefore, federal agencies should take a hard look at their scientific processes to ensure that they are fully, and from the very beginning, incorporating equity and justice into their framework. It is not enough for federal agencies to simply carry out data collection efforts on health disparities, they must ensure that all processes guiding the science are robust, community-focused, and free from political interference. Agencies should develop protocols that allow community input throughout the research process, and allow enough time for communities to comment on these processes.
“Community science (also called citizen science) is one promising way forward. Because community science allows community members to exert a high degree of control over research, focuses primarily on addressing community concerns, and forms a strong collaborative process between scientists and community members, it has great potential to serve as an important tool that federal agencies can employ to help meaningfully engage with underserved communities. Agencies should develop clear guidelines on how to encourage innovative community science projects, provide standards and tools for communities to best inform the process, and help agencies determine how and when to use and prioritize community science to support regulatory decision making.”
Scientific integrity training
Jacob Carter emphasized in the science and education session that, “Scientific integrity training will be especially important as new federal scientific experts are hired into agencies replacing the thousands lost during the past four years. When thinking about ways to strengthen scientific integrity trainings, the task force should consider that many new hires will be early-career scientists who may not be well versed on the principles of scientific integrity in the context of federal agency process–and these individuals also will likely be aware of the unprecedented frequency of attacks on science that occurred during the past four years. Therefore, scientific integrity trainings will not only be essential for educating scientists on their rights and protections, but to show new hires that federal agencies prioritize a workplace culture that respects scientists and the work they do. Agencies also must recruit a diverse pool of early career scientists in their rebuilding efforts. This commitment to diversity should be made explicit in these efforts, such as EPA’s plan to hire 1000 new staff by next May.
“All federal employees should receive periodic, comprehensive training on scientific integrity: what it is, how it manifests in day-to-day work, and what violations actually look like. These trainings are important for employees who use science to a significant degree in their work, but also equally important for political appointees. Scientific integrity officials and federal scientists should receive training to identify and report discrimination, harassment, or bullying within their professional environment.”
Taryn MacKinney in the use of scientific information session said, “You’ve heard excellent policy ideas today, but all of them are for naught without consistent enforcement and remediation. It’s particularly problematic when agencies encourage employees to report violations, but then can’t or don’t punish violators and reverse harms. These gaps weaken federal science, and prevent science-based decisions from helping those who need them most. We urge OSTP to consider that all federal agency employees [and the public] must know what constitutes a violation, and how to report it—and agencies must establish inviolable safeguards to protect these employees from retaliation. Agencies must have the power to conduct speedy investigations and enforce appropriate penalties for violators. Violators must face consequences strong enough to deter transgressions in the future and establish a culture of scientific integrity. This must also apply to political officials, no matter their rank. When policies lack the teeth of enforcement, bad actors in our government take advantage. And those harmed most by weak protections for federal science are people of color; low-income, Indigenous, and immigrant communities; and children.”
And Genna Reed concluded that, “Independent science—that is, science free of political, ideological, or financial influence—helps our government make informed decisions to protect public health and safety, and enhances public trust. However, conflicts of interest have endangered independent science and its use in decision making. These conflicts can undermine public trust, weaken civic participation, erode the credibility of individuals or entire fields of expertise, and ultimately harm people and our environment. Where federal policy decisions must be informed by scientific evidence, in addition to strong scientific integrity policies, we need qualified individuals who are unencumbered by conflicts of interest and able to make decisions that benefit the public. Thus, agencies must first define conflicts of interest. That means ensuring that taking public policy positions, receiving federal research grants, and being a member of a scientific association are explicitly not considered conflicts because they do not preclude an objective assessment of scientific information.
“Second, enforce ethics laws, and establish guidelines about conflicts that disqualify individuals from decision making authority or participating in science committees or peer reviews. Third, publicly disclose the conflicts of interests and recusal statements of all political officials and science committee members in a timely manner, in accordance with specific disclosure deadlines. And, finally, require that all scientific leadership positions are filled with people with relevant training or experience and without real or perceived conflicts of interest. With OSTP’s leadership and guidance, agencies will be better able to clarify, make public, and consistently abide by practices that prevent conflicts of interest in science-based decision making.”
A better process
We have made these and many more recommendations for how this and any other administration can and must improve the process by which independent science informs policy making. It is exciting for us science and democracy nerds to work with an administration that seems to take so many of our long standing recommendations to heart.
But the listening sessions raised some other points that should be considered by this important White House office. The notice given for the listening sessions was about two weeks. Registration was required for all these sessions and they were all held during normal working hours. Once registered, those who wished to speak could log into the session, but were not given a specific time when they would be called during the two-hour session. For us at UCS, we adapted to the short notice and sessions during the working day with potentially up to a two-hour wait online to speak. But these barriers made the sessions inaccessible for many community activists, and particularly those from marginalized communities who have one (or more!) full-time day jobs. And for those who weren’t able to join, the recorded sessions still haven’t been posted online, nor has OSTP made public meeting participant rosters or meeting minutes.
Scientific integrity might seem like a wonky technical issue, but it has far reaching effects and we need a diversity of perspectives at the table in order to get it right. In the future, more accessible sessions for those outside the DC area are important.
The next step in the OSTP process is to develop a comprehensive review of existing scientific integrity policies and practices in line with the President’s memorandum of January 27th, 2021. We hope and expect that review will be released in the autumn with another, longer opportunity for public comment. Thanks to all of my colleagues and everyone else who were able to participate in the listening sessions, or to make comments in writing to OSTP on scientific integrity.