Rulemaking and other policy decisions at the Environmental Protection Agency (EPA) almost invariably rely on science, with the nature and extent of that reliance varying considerably from one instance to another. But one factor is constant: quality must be a first-order concern in deciding what scientific information is relevant, how it is presented, and how it is used. Quality science includes the following characteristics: clear identification and prioritization of the most important scientific questions to be addressed; identification and use of the most appropriate and powerful experimental and analytical designs; employment of state-of-the-art experimental techniques; accurate measurements; validation and independent review processes; and recruitment, retention, and reward of high-quality scientific personnel.
Regulatory and research science at EPA is performed in its 12 research and development laboratories, its 23 regional and program office laboratories, and its program and policy offices. Many contributions made by EPA scientists are widely respected by the research community. For example, its analytical methods, predictive models, and risk-assessment guidelines are used as standards by other agencies, nationally and abroad.
Nonetheless, the role of science in EPA policies, decisions, and
EPA must begin to focus its energies and resources in five key areas if it is to bring its domestic recognition to the same high level the agency enjoys internationally, as a science agency as well as a regulatory agency. The first is in the recruiting, nurturing, and development of its entry-level scientific staff. There is currently a highly skilled, well-recognized scientific workforce in the Office of Research and Development that is nearing retirement and will need replacing, due to FTE limitations. EPA has not previously demonstrated capabilities in this area. Scientific and technical factors often receive insufficient weight in developing job descriptions, setting performance standards, designing training programs and career-development opportunities, creating career ladders, and rewarding achievement.
Second is peer review, quality assurance, and quality control. Regulatory decisions are most likely to be cost-effective if they are based on risk assessments or other technical work-products that embody state-of-the-art scientific principles, models, and data. One important procedure for obtaining such high-quality products is peer review- that is, independent reviews by unbiased subject-matter experts. Another key procedure is to require that the underlying data be gathered in accordance with strict quality-assurance guidelines. Although such procedures exist within EPA, they are not consistently used. Historically, policy decisions have often lacked credibility because they were based on work-products that either were obviously flawed or lacked the endorsement of outside experts. As a consequence, EPA regulatory decisions have been frequently perceived by Congress, the Office of Management and Budget and other federal agencies, industry, or the public as unsound.
Third, good laboratory systems are necessary to maintain quality science. Scientists cannot be effective without a quality infrastructure for all EPA laboratories. This includes state-of-the- art facilities and instrumentation, well-equipped libraries, high- performance computing and telecommunications resources, and a responsive procurement and budgeting system. Moreover, if policymakers are to benefit from improvements to the science base, more strategically focused investment in R&D is imperative. Recent studies have noted that the R&D effort at EPA is neither large enough nor focused enough to meet the mission requirements.
A fourth area necessary to sustain quality science is administrative oversight for R&D. Reductions in science and engineering career positions in recent years not only have fostered undue dependence on contractors but also have encumbered EPA scientists with new contract management duties-thereby shifting their focus and their talents toward administration and away from what they do best. Moreover, laboratory scientists are unnecessarily encumbered by inflexible budgets and the fact that job positions and contract dollars are not interchangeable.
Finally, communication and coordination between EPA policymakers and scientific staff are too fragmented to be effective. For example, inadequate coordination among programs and the laboratories has led to science being practiced in isolation and with no apparent impact on the research agendas of other agencies.
1. EPA should work to establish guidelines for professional development and promotion of scientific and technical staff.
EPA should review and evaluate best practices of other federal science agencies for example, the National Institutes of Health, which have made progress in developing successful personnel systems and tenure tracks for scientific and technical employees.
2. EPA should expand the use of peer review and quality-assurance procedures to promote excellence in science.
Through specific policy guidance from the Office of the Administrator, existing procedures for peer review and quality assurance would be integrated further into EPA programs.
3. The EPA Administrator should assess the organizational effectiveness and appropriate structures of EPA's laboratories.
The President's budget request for fiscal 1994 includes funds for a study to address research needs and to identify options for making EPA's research more efficient. As a part of the study, EPA should also identify management and administrative processes that can be streamlined.
4. EPA should develop a plan to integrate opportunities for increased scientific communications within and outside EPA.
Through increased use of workshops, temporary reassignments, and other methods, EPA scientists would gain more opportunities to stay current with the advances in environmental science and its applications. In this way, EPA can better keep congressional staff, members of the news media, and the general public informed about the state of the environment and
Improvements in the quality of science at EPA will result in renewed credibility and stature for EPA's scientists. In addition, regulatory decisionmaking will be based on optimal scientific analysis.
There are no additional costs associated with this issue.
1. See U.S. Environmental Protection Agency, Expert Panel on the Role of Science, Safeguarding the Future: Credible Science, Credible Decisions (Washington, D.C., March 1992).
2. Carnegie Commission on Science, Technology, and Government, Environmental Research and Development: Strengthening the Federal Infrastructure (Washington, D.C., December 1992), pp. 62-68.
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