With less than 30 days left in the deadline established by the federal scientific integrity memo, I anticipate that the delays experienced at the federal level will be replicated at the agency level. The Interior Department is the only agency to have released a policy since the federal memo was released in December. (The Environmental Protection Agency developed something resembling the March 2009 Presidential memo nearly two years ago.) Regular readers may remember this process had a long first act, so a long second act should be no surprise.
The National Oceanic and Atmospheric Administration (NOAA) has been circulating a draft scientific integrity memo since February, and Public Employees for Environmental Responsibility (PEER) has released a copy (H/T The Intersection). PEER has been following these policies closely, having initiated a Freedom of Information Act (FOIA) lawsuit after the Office of Science and Technology Policy was less than forthcoming (in the opinion of PEER) in response to a FOIA request. PEER has continued its criticism of scientific integrity policies in connection with the draft NOAA memo.
Keeping in mind that this is a draft memo, here is my summary and analysis:
Like the Department of Interior policy, the NOAA policy provides definitions of relevant terms, and give some outline of a process to handle allegations of scientific misconduct. However, that process is not nearly as detailed in the NOAA policy, in part because a relevant procedural handbook is still under development. The NOAA policy also lists codes of ethics for both scientists and science supervisors and managers (sections 5 and 6). While the Interior Department policy also distinguishes the responsibilities of both researchers and their supervisors/managers, I find the clearer distinction in the NOAA policy a better idea. It places the responsibilities of both parties on a more equal plane, though as PEER describes in its criticisms, there are still a lot of things supervisors could do to restrict scientific conduct that aren’t well defined (or at least well referenced).
Administrator Lubchenco seems committed to making the policy work, and is saying some of the right things:
“I’ve said it before and I’ll say it again: a key role of science is to inform policy. I use the word ‘inform’ judiciously: science should not dictate policy, it should inform it. Policies will and should be based on a number of factors, including values, politics, economics, etc., but science should be well represented at the table. And that science needs to be trustworthy.”
However, much like with the Interior Department, the real test of this commitment will be in implementation. PEER has apparently had issues with NOAA’s prior conduct on pre-release screening of NOAA science research and withdrawing support from funded scientists over advocacy, so I understand their skepticism concerning this policy. And of course, this is still a draft policy. It may be far from perfect, but it is easier to improve a proposed policy than to craft a better one from scratch. Either way, the unfinished procedural manual mentioned several times in the policy needs to be completed and released at the same time as the final policy. Otherwise the can has been well and duly kicked further down the road.
P.S. I think the U.K. could well do with incorporating this language into their comparable policies on scientific conduct:
“Employees are free to present viewpoints within their area of professional expertise that extend beyond science to incorporate personal opinion but must make clear they are presenting their individual opinions – not the views of the department or agency – and clearly state their opinions be referenced as such.”