>> Francesca Grifo: Hello, everyone.
Thank you very much for being here.
It's my pleasure to talk to you this morning about
scientific integrity.
My name is Francesca Grifo and I'm the scientific
integrity official at the Environmental Protection Agency.
I'd like to start with this slide because it reminds me
of one of the big reasons why we worry about
scientific integrity.
This is a quote from William Ruckelshaus, who came back
to the agency for a second term as its administrator.
And he talked about how the agency -- folks at the agency
should conduct themselves with the openness and
integrity which alone can ensure public trust
in the agency.
Public trust is a key piece of scientific integrity;
it's a key piece of why we care about it.
And it's -- the reason you're looking at a fishbowl
is because it's called the Fishbowl Memo.
So, just in case you were wondering why there's a goldfish.
But another part of the agency's history on
scientific integrity, were the principles of scientific
integrity that were created by the National Partnership
Council in 1999 -- again, most of this content has
been subsumed into the Scientific Integrity Policy,
so I'm not going to spend a lot of time on these.
But the current policy that we have has its origins in
President Obama's inaugural address in 2009, where he
pledged to restore science to its rightful place.
This was followed up very quickly, a few months later,
with the Scientific Integrity Memorandum.
This memorandum gave the Office of Science and
Technology Policy 120 days to create guidance
for the agencies.
They did make -- create that guidance, and the agencies
then each created their own scientific
integrity policies.
EPA was right out there at the front.
I think we were the second agency, actually, to come up
with a draft policy, right after the
Department of the Interior.
That was in August of 2011; we had a very strong, robust
comment period with many, many public comments coming
in and released a much-strengthened policy in
February of 2012.
So I think I'd like to start by just helping you to
understand: What is scientific integrity?
So we think of it as adherence to professional
values and practices.
That part of it is probably quite familiar to you, but
the part that may not be as familiar is actually that
it's not just about conducting the science.
It's about conducting, communicating, and applying
the results of that science, as well as supervising
that science.
So it's a broader definition than we might be familiar with.
Obviously our goal in all of this is objectivity,
clarity, reproducibility, and utility.
That's what we want from our science.
But we also want something that's going to provide some
insulation for us from bias, fabrication, falsification,
plagiarism, outside interference, and censorship.
One of the important things at EPA is that we also have
a Scientific Misconduct Policy.
That policy is adjudicated or carried out by the Office
of the Inspector General, and that's what deals with
bias -- I mean -- I'm sorry - with fabrication
and falsification.
The plagiarism part has been recently passed to the
Scientific Integrity Group, so we're dealing with that.
So what's the challenge?
What is it that we're trying to address here?
What is it that we're trying to prevent?
What we're trying to prevent is the manipulation,
suppression, or the delay of science or scientific
reports, other scientific products.
We want to have transparency around agency
decision-making, right?
We don't want a lack of transparency.
We want to eliminate partiality or conflict of
interest in peer review or advisory committees, and we
want to get rid of a culture that's unwelcoming to
dissenting opinions.
It's very important to us that we can have those
robust conversations about the science that actually
get us to the quality, rigorous, independent
science that we want in the end.
We don't want agency end users directing research and
results either, so that - those are the big challenges
that we face.
The Policy, though, is very broad, and I think this is
one of its strengths.
It does not just apply to employees at the agency.
It applies to contractors, grantees, volunteers, and
collaborators -- so, a very broad group.
And again, just to emphasize, not just those
who conduct that science but those who supervise, manage,
influence those scientific activities; those who
communicate that information in an official capacity, and
those who utilize that information in making agency
policy or management decisions.
So it's very broad.
Just to look at this graphically, this is sort of
the typical stuff in the green boxes that we think of
when we think of the conduct of science.
We're very lucky here at EPA; we have a very strong Q.C.
and strong peer review.
But that's the process that you're familiar with.
And this is really what we think of as research
integrity in the most formal sense.
But we also supervise that science.
We communicate that science.
And we utilize that science in decision-making.
And these are the pieces that we've added on, and
together we have our scientific integrity.
So scientific integrity is not just the conduct; it's
all these other pieces as well.
Another way of looking at this and understanding what
we mean by "scientific integrity" is to look at
what it is that we do to that makes sure that the
science is great.
We have our scientific methods validated; we spend
a lot of time and energy on this.
We work hard to have very qualified scientists;
we have very strong accreditation of our labs
and facilities all across the agency and the regions
and throughout; and we have a very strong information
quality and quality assurance program.
These are all the things that we're doing to make
sure that the science is great.
In addition, we ensure that we use peer review in our
federal advisory committees appropriately; we make sure
that we don't have conflicts of interest; we make sure
that we have a free flow of science and that we have
management review that's based on scientific quality.
And of course the timely release of our products; we
don't want to sit on them forever.
The result is an open culture of science -- an open
scientific culture, honest investigation, a firm
commitment to evidence, and a culture of robust
scientific inquiry and discussion.
All very important pieces of our scientific picture.
And in the end, what we hope is that what this all leads
to, going back again to public trust in agency
science, transparent scientific processes and
open communication of science, and most
importantly, perhaps, scientific conclusions that
are not influenced by their policy implications.
They're independent.
And scientists, of course, able to do their best work.
Again, we keep coming back to the importance
of our scientists.
Another, you know, key piece of why the policy works is
that we have a Scientific Integrity Committee.
It's made up of deputy scientific integrity
officials representing each of the agencies, program
offices, and regions.
It's important for you to know who your scientific
integrity official is.
And I'll give you a website at the end where you can
look up who is your deputy scientific
integrity official.
Now, the policy itself has four sections.
It's fourteen pages long.
I'm not going to go into, obviously, all of those
fourteen pages; you can read it.
It's easy to find on the website.
But these are the four sections that it talks about.
So what I am going to do is, I've picked just a few
highlights, a few pieces that are very important of
the policy to tell you a few things about.
The first one is the Right of Last Review.
What this means is, as scientists, you have the
right to review the science.
So if you work on a project and that project then gets
translated for a different audience you have the right
to go back and look and make sure that that science has
been translated correctly.
Do you get to review the policy?
No.
Do you get to review what people say that science is -
what they're going to do with that science?
No.
But you do get to go back and actually review the
scientific content.
And again, nothing nefarious has to happen for this to go
wrong; the most well-intentioned people can
take very complex scientific concepts, translate them for
a different audience, and lose some of the nuances of that science.
Another important piece of the policy is, it gives you
your Personal Views Exception.
What this means is, you can take your government hat off
and speak as a private citizen.
This is very important because you still have to
pay attention to the Ethics Rules at the agency.
Right?
You have to be pragmatic in the use of this right, and
it does not protect you from the consequences
of speaking out.
So I try to say to people, "What is your goal?
What is it that you're trying to achieve, and what
is the most effective way to get to that goal?"
It may or may not be by using the Personal Views
Exception, but do be aware of your ethics questions,
such as, "Are you being compensated?
Is it political?
Is it lobbying?
Is it electioneering?
Is it public data?
Is it agency data?"
So it's fairly complex, but it is in there and it's
important that you know that.
Another key strength of the Policy is that it very
explicitly states that all EPA employees are prohibited
from suppressing, altering, or otherwise impeding the
timely release of scientific findings, and we'll talk
more about this.
It also encourages the professional
development of scientists.
What do we mean by "professional development?"
We mean publishing, holding office in professional
societies, editing journals, accruing professional
awards, getting the training that you need -- but again,
this is one that's complicated.
And because it's complicated we've actually created in
Skillport a module that talks about the ethics of
professional development.
But today we're here to do a training.
The training that we're doing today has
five objectives.
I want you to know the definition of "scientific
integrity;" I want you to know where to find
information about scientific integrity; I want you to
understand how scientific integrity enhances the work
that you do; it's not just another box to check.
It's something that's very key to the success of our
work at the agency.
I want you to understand how -- what constitutes an
allegation of a lapse in scientific integrity -- in
other words, where is it that we go off the track and
things go wrong?
And I want you to know how and where to report an
allegation of a problem with scientific integrity.
So those are the training objectives.
For more information about scientific integrity at EPA
you can go to our website.
It has an enormous amount of information.
Now I'd like to turn to the video.
>> Female Speaker: The responsibility for making
sure our science has integrity belongs to all of us.
The U.S. Environmental Protection Agency
has many policies and
practices to ensure it uses robust and independent
science in all its decision-making.
It is the responsibility of every EPA employee,
contractor, grantee, volunteer, and collaborator
to conduct, utilize, communicate, and supervise
science with honesty, integrity, and transparency
both inside and outside the agency.
The EPA's Scientific Integrity Policy prohibits
anyone from suppressing, delaying, or altering
scientific findings.
Enabling the free flow of scientific information,
attention to quality control, consistent and
appropriate use of peer review, and professional
development for agency scientists are some of the
tools EPA uses to accomplish this.
"Scientific integrity" means we adhere to professional
values and practices, ensure objectivity, clarity,
reproducibility, and utility of our science, and provide
insulation from bias, fabrication, falsification,
plagiarism, outside interference, and censorship.
We must speak up if we see suppression or barriers to
the timely release of scientific findings.
If we see or experience intimidation or coercion to
alter scientific data, findings, or professional
opinions, we must speak up.
If anyone reports interference in the
integrity of science you must listen openly, judge
fairly, and act accordingly.
Allegations of a loss of scientific integrity may be
reported to a variety of officials.
Some good places to start are the deputy scientific
integrity officials, the scientific integrity
official, and the Office of Inspector General.
Together we can ensure EPA's work is transparent and
based on robust science, and that communication of EPA
science is accurate and timely, for this alone can
ensure public trust.
The Scientific Integrity Policy enhances EPA's
ability to carry out its mission to effectively
protect human health and the environment.
>> Francesca Grifo: Okay, who's responsible for
scientific integrity at EPA?
>> Audience: All of us.
>> Francesca Grifo: Exactly.
All of us, right?
And what is scientific integrity?
>> Audience: Adherence to professional practices.
>> Francesca Grifo: Exactly.
When we're doing all those things, right?
Conducting, supervising, communicating, and
utilizing science.
Terrific.
What are your questions?
Yes.
>> Female Speaker: Where is the line between science
and policy?
>> Francesca Grifo: Good question.
Okay, the line between science and policy I think,
is a hard one sometimes for scientists to understand and
actually draw.
Part of that is, when we typically publish we have
the sections of a scientific paper; we have the
introduction, and so on and so forth, and we merge those
things frequently in those sections.
So it's very hard to make that distinguish.
But here's what I tell people: When you are in the
"research" and the "research results", those sections,
you're very firmly in the science realm.
When you start to talk about what that science means
you're kind of creeping towards the policy realm,
and when you really talk about what are we going to
do with that science, what is it used for, then you are
squarely in the policy realm.
So it really is going to be an individual answer
to that question.
That's the -- those are the guidelines.
Other questions.
Yes.
>> Female Speaker: What do you mean by
delay of science?
>> Francesca Grifo: Yeah, another good question.
You know, "delay" can mean not a lot of things.
What we like to think about is that, if a product is
finished on June 20th, does that mean we have to release
it on June 21st?
No, of course not; we can have a strategic window.
There are lots of other factors going on at the
agency, and that's what we think about when we think
about rolling out a product or releasing research is,
what's going to be the best context for it?
Now, is that best context going to be a year,
or two years?
No, right?
It shouldn't be that long.
A month, six weeks, eight weeks, probably that's not a
delay in science.
So again, there's not an easy exact answer to that
question; there's going to be a range.
But I think if something's sitting on a shelf for over
a year you can be pretty sure that you should be
talking to the scientific integrity official.
Other questions.
Yes.
>> Female Speaker: What if I disagree with the science
underpinning a policy decision?
>> Francesca Grifo: Yeah, that's a hard one too.
Basically the Scientific Integrity Policy talks about
how you can have a differing scientific opinion.
And what that means is, if you have concerns about that
you can put your differing scientific opinion in
writing, and that opinion will travel with the rest of
the scientific conclusions all the way through the
various decision-makers; it also might find itself as
part of the charge to a peer review and be, you
know, resolved at one level or another.
Now, that being said, the Policy -- we will be putting
out a more specific Differing Scientific
Opinions Policy that will help to walk people
through that.
But yeah, it's very important.
I mean, and if we have those kinds of concerns we
should have a way of expressing them.
One more.
Yes.
>> Male Speaker: Well, can I talk about EPA-related
issues as a private citizen?
>> Francesca Grifo: You can, and you should.
In fact, I really encourage people to be out and about,
talking about the work that we do here, because I think
we do amazing work.
But again, there are constraints on that.
When we came to work for the agency we took an oath, and
no matter what we're doing, whether it's a personal
activity outside of work or an activity within work, we
have to be thinking about, you know, the ethical
constraints that are on our - the things that we can
talk about.
But yes, you can talk about those things.
You have to be -- again, I would think about the ethics
rules and perhaps even consult, if you can
anticipate it ahead of time, with an ethics official.
Another key point there is, it's very hard to stand up
and say, "I'm not representing EPA" when
you're at a scientific society meeting, for example,
and you have a badge on that says your name and "EPA".
It's very hard to stand up and speak as not EPA, for
example, when you're on the agenda for a community
meeting as being from EPA.
So you have to kind of think about it broadly in
those terms.
But no, we are not muzzled as scientists.
Terrific.
Thank you very much for your attention.
I hope that this information really helps you to further
enhance the culture of scientific integrity at EPA.
Thanks again.