ACS Position Statement

Scientific Insight and Integrity in Public Policy

Scientific Insight and Integrity in Public Policy

Summary

Our government faces a wide range of critical and complex issues that involve significant technical challenges, as well as important economic, legal, and political components. The American Chemical Society (ACS) strongly supports the use of insightful and comprehensive scientific and engineering research and analyses to assist the development and evaluation of policy options to deal with these challenges. The Society encourages policies that assist the government to obtain and integrate scientific assessments including transparency, openness, empowerment of scientists inside and outside of government, and an appropriate scientific advisory system.

ACS Position

Most national challenges require careful, comprehensive scientific and engineering research and analyses to elucidate and evaluate policy options. Such issues also involve important economic, legal and political components. These challenges include environmental pollution, climate change, sustainable energy supplies, persistent and emerging diseases, safe and effective medicines and medical procedures, safe and reliable food and water supplies, ecosystem preservation, aging infrastructure management, industrial innovation and competitiveness, and effective defenses against terrorist and military threats. In a world with strongly coupled economic and environmental systems, many of these challenges require global responses.

Dealing with technically complex issues inevitably creates tension between technical and non-technical stakeholders: The definition of technical challenges, development of potential responses, and analysis of probable impacts often become intertwined with disparate political, economic, or cultural interests. Unfortunately, during the last decade, resulting tensions have become increasingly common, and the traditional mechanisms for securing insightful, unbiased technical input are showing significant signs of strain.

For example, in 2007 the House Energy and Commerce Subcommittee on Oversight and Investigations subpoenaed extensive research records and testimony as part of an evaluation of studies delineating human-induced global warming. National Research Council and international reports plus subsequent research had substantively confirmed the findings, but advocates in the political arena attempted to discredit both the scientists and the studies. Such incidents complicate the process and undermine confidence in the resulting advice.

In order to lower this strain, it is desirable to return to an earlier definition of appropriate roles in the policy process. Scientists and engineers have an obligation to provide transparent, unbiased and understandable technical analyses that include all relevant scientific insights. Policymakers have an obligation to avoid applying political or other non-scientific criteria to reject, restrict, or reinterpret policy relevant technical input.

Many executive branch agencies employ large numbers of excellent scientists and engineers directly or through federally funded centers. Federal funding also supports the work of many academic and private sector scientists. Further, because the federal government cannot directly employ the full range of expertise and experience required to address the wide variety of technical issues it faces, the executive branch has also relied on numerous scientific and technical advisory committees that draw on the wider technical community to assess scientific knowledge and develop policy recommendations. Traditionally, in the absence of classified or otherwise highly sensitive information, this triad of federal scientific and engineering activities has operated with a spirit of open inquiry and debate that has served the nation well.

Since the 1995 demise of its Office of Technology Assessment, Congress has employed relatively few scientists or engineers to thoroughly assess and evaluate the technical dimensions of potential legislation. Congress relies on the relatively limited technical resources of the Congressional Research Service and the Government Accountability Office for fast-response, scientific analyses and recommendations. In addition, the National Research Council is available for more comprehensive input. Congress has also struggled with uneven public availability of data from federally supported research used to set regulations. Clear and consistent guidelines and procedures are needed to ensure the required data transfers occur without unduly burdening the scientists involved.

The severe lack of congressional technical assessment capability is only partially moderated by about 35 technically trained congressional policy fellows supported annually by ACS and sister scientific societies. These fellows and about as many former fellows in full-time congressional staff positions have made significant impacts in the offices where they serve, but they can only cover a small fraction of the member and committee offices that would benefit from access to regular scientific insight crafted for a policy audience.

Most scientists and engineers have few illusions that complex policy decisions will or should be made on technical grounds alone. But if artificial constraints are used to limit scientific input into policy deliberations, the nation’s best scientists and engineers may well be discouraged from engaging in the difficult tasks of creating, assessing, and interpreting scientific information for the policy evaluation and decision-making processes. Such constraints are not in the nation’s interest. The means and methods of providing our federal government with adequate scientific insight and ensuring the scientific integrity of resulting technical analyses and policy recommendations are in some disarray and need to be clarified, strengthened, and more consistently supported.

Recommendations

ACS believes that incorporating scientific and engineering data, analyses and insights into the development and evaluation of policy options is critical to the federal government’s ability to address many national challenges. However, the value of science used to inform policy depends on both its completeness and its integrity. Completeness requires the inclusion of all current, pertinent scientific insight, which then should be presented as succinctly and understandably as possible. It is particularly important that uncertainties be identified, quantified, and explained. Selective use of partial data or biased analyses to buttress preconceived policy is both unethical and ill advised. Ensuring the integrity of science used to support policy recommendations requires sustained effort and goodwill by both technical and non-technical policy participants.

A free marketplace of policy relevant information is required to produce effective policy recommendations. Scientists and engineers serving the federal government as employees, grantees, or advisors can contribute more effectively with few, if any, constraints on their ability to present and publish their research and analysis results in forums subject to review by their peers. While some sensitive information may need to be classified or otherwise controlled, policy options based on technical information debated and vetted by the full scientific community are more likely to be sound and successful than those based on incomplete information or restricted review. Scientific data and analyses should be assessed and summarized by qualified peers and should not be filtered through reviewers who are not objective or who have conflicts of interest.

To clarify and strengthen the role of scientific insight and integrity in the development of public policy, ACS recommends the following:

1. The federal legislative and executive branches should constantly review and improve their ability to get unbiased scientific and technical input for policy development.
2. Government policy analysts should ensure that scientific input draws from and references all relevant, peer-reviewed sources. Unpublished and non-peer reviewed sources should be available and open to review by all stakeholders. Quantitative results with careful uncertainty and sensitivity analyses should be the norm. Conflicting results should be quantitatively assessed, evaluated, and, if possible, reconciled by technical experts.
3. Data used to develop federal policy, in spite of the source, should be publicly available and easily accessible. However, the scientific enterprise should not be burdened unreasonably by extensive or repetitive requests for information.
4. Federally employed and federally funded scientists and engineers should be allowed and encouraged to present their unclassified research at appropriate technical symposia and to publish in peer-reviewed journals without interference.
5. Federally employed and federally funded scientists and engineers generally should be allowed to discuss their published, peer reviewed research in public forums, with representatives of the media, and in written work prepared for the general public.
6. Federally employed and federally funded scientists, engineers, and members of federal scientific and technical advisory committees generally should be allowed to comment publicly on policy options informed by their research results and general technical knowledge.
7. When federal agencies must prevent their employees, grantees, and/or advisors from commenting publicly on scientific results or policies, restrictions should be transparent and consistently enforced. Appeal processes should be easily available and timely.
8. Federal agencies should utilize scientific and technical advisory committees composed of qualified scientists and engineers from outside the sponsoring agency to enhance and stimulate the efforts of their technical staff members. Membership of federal scientific and technical advisory committees should be based on appropriate technical expertise, breadth of experience, availability and willingness to serve. Employer, professional or political affiliation, and prior policy positions should not preclude someone from being included on scientific/technical advisory committees.
9. Congress should strengthen its access to timely science and technology information evaluations and policy option analyses. Congressional committees can and should seek direct testimony from technical experts on scientific and policy issues. Detailed evaluations and analyses of technical data also need to be performed and presented publicly by scientific or engineering professionals with appropriate backgrounds and training.