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SKAPP Comments on Presidential Memo on Scientific Integrity

May 13, 2009 - The Project on Scientific Knowledge and Public Policy (SKAPP) submitted comments to the White House Office of Science and Technology Policy (OSTP) regarding the implementation of scientific integrity principles that President Barack Obama laid out in a Presidential Memorandum on March 9, 2009. The memo tasked OSTP with developing recommendations based on six principles of scientific integrity, including having appropriate policies in place, maintaining transparency, and using peer review where appropriate. OSTP requested public comments to assist them in developing their recommendations.

SKAPP staff members Liz Borkowski, Ruth Long, David Michaels, and Susan Wood submitted two sets of comments; the first focused on overarching issues of scientific integrity, and the second focused on issues raised during SKAPP's Scientists in Government research. In the first set of comments, they recommend:

To eliminate conflicts of interest, federal agencies should adopt policies modeled on those of the World Health Organization’s International Agency for Research on Cancer (IARC) to end the use of conflicted experts on their scientific advisory committees, and should ensure that their requirements for conflict-of-interest disclosure are clearly communicated to advisory committee members, contractors, and employees alike.
To ensure that agencies’ use of outside research upholds standards of scientific integrity, federal agencies should adopt requirements for “research integrity” comparable to those used by the International Committee of Medical Journal Editors, and require that regulated entities submit information about adverse outcomes related to their products or practices.
To ensure that peer review is used appropriately and does not provide an opportunity for unwarranted political interference, agencies should not be required to subject their materials to additional peer review beyond what is used for journal submissions and in the public comment process.
To advance transparency, agencies should require that the raw data for any research studies used in policy decisions be made available to those who request them, and adopt policies to limit what is currently excessive use of the “confidential business information” designation in information submitted to agencies pursuant to policy decisions.
To reduce delays and opportunities for political interference, the OMB’s role in science-related agency activities should be limited. This does not correspond to a particular principle in the Presidential Memorandum, but is essential to the effort to uphold the highest standards of scientific integrity.

In the second set of comments, based on preliminary results from the Scientists in Government research, they recommend:

To contribute to retention and effectiveness of federal scientists, managers
hired to oversee scientists should have both scientific backgrounds and strong managerial
skills.
With regards to the appropriate rules and procedures to ensure scientific integrity, agencies should adopt policies and procedures to protect science from
interference that may come from within or outside the agency; at the same time, agencies
should assess the possibilities for streamlining the internal review processes for scientific
documents, to ensure that integrity goals are not leading to misguided burdens on
scientists’ time.
To ensure timely access to research findings and other scientific materials,
agencies should streamline their clearance processes for scientific materials that are to be
published or otherwise disseminated.
To ensure that scientists feel able to speak up about possible compromises to scientific
integrity, agencies should assess the grievance procedures and feedback
mechanism available to scientists who have concerns about research protocols or
processes.

OSTP's deadline for developing its recommendations is July 7.