Ask Dr. H – Scientific Integrity Memo In Effect Since Last March (?)

In this week’s Ask Dr. H. segment (which did not run last week as Dr. Holdren was on travel), Jason asks about the long-delayed plan requested from the Office of Science and Technology Policy (OSTP) to help ensure scientific integrity across the federal government.  It’s a question that’s been on my mind since at least last November, when the requested plan was already four months overdue (if not more).  It’s not the first time Jason’s question has been asked of Dr. Holdren, but it may be the one that gets the most attention, given it’s much easier to find online than the hearing where Dr. Holdren first acknowledged the delay in the plan.

His detailed response is consistent with his remarks from this past February, and from his response to the same question asked of him in April (by me) at a science policy conference.  And while I don’t have any reason to think that the response isn’t genuine, I still have some problems with it.

Let’s start with the list of principles and issues related to science integrity outlined in the original Executive order and re-emphasized in Dr. Holdren’s response.  Dr. Holdren asserts:

“There should not be any doubt that these principles have been in effect—that is, binding on all Executive departments and agencies—from the date of issue of the Memorandum on March 9, 2009.”

That he has been repeatedly asked this question strikes me as evidence that there is doubt, whether or not some of that doubt is politically motivated or simply confusion at the lack of explicit direction.  The OSTP could have taken an excellent step towards dispelling this doubt by adding language to the Request for Comment similar to what Dr. Holdren used above.  That request is pretty silent on whether or not the March 2009 memo was already in effect or not.

This is not a criticism that the memo is not in effect.  While the bulk of the explicit direction in the memo concerns the recommendations for further Presidential action on scientific integrity, it seems reasonable to assume that the principles outlined in the first part of the document are meant as guidance.

The problem is that this guidance is not particularly forceful in its language (no “Executive branch agencies should…” language here).  Add to this the limited communications from Dr. Holdren or OSTP emphasizing that those principles were in effect, and I think it reasonable that people would have doubts.  Perhaps Dr. Holdren wouldn’t be getting these questions if he’d add to his common refrain that ‘this President gets science’ that the administration is working under the principles for scientific integrity outlined in the memo.  I note in the end of his response that Dr. Holdren emphasizes the Obama Administration’s initiatives in open government data.  That open government push has been much better expressed throughout the government than the scientific integrity push.  There didn’t have to be this discrepancy, but it’s there.

I understand why there’s been a problem – what’s been asked is a tough task.

“I am the first to admit that the process has been more laborious and time-consuming than expected at the outset. Determining how to elaborate on the principles set forth in the Memorandum in enough detail to be of real assistance in their implementation, while at the same time retaining sufficient generality to be applicable across Executive departments and agencies with a wide variety of missions and structures, has been particularly challenging.”

Anybody who thinks this should be easy isn’t paying attention.  But where’s the harm in acknowledging the problem much, much closer to the first missed deadline?  Especially when coupled with a statement emphasizing that the Administration is already committed to the principles outlined in the March 2009 memo.  There’s still no excuse for OSTP not to have been out in front of this.