ACS Position Statement

Scientific Insight and Integrity in Public Policy

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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. These challenges include environmental pollution; climate change; sustainable energy, food, and water supplies; ecosystem preservation; aging infrastructure; persistent and emerging diseases; safe and effective medical treatments; industrial innovation and competitiveness; and terrorist and military threats.

Complex issues frequently create tension between technical and nontechnical stakeholders. Technical approaches to problems often are intertwined with disparate political, economic, and cultural concerns. Unfortunately, the resulting tensions have become increasingly common, and traditional mechanisms for securing insightful, unbiased technical input are under strain.

The federal government engages scientists and engineers in a variety of ways:

• As direct employees or as contractors at government facilities
• Through federal grants or contracts that support academic and private-sector scientists
• Through scientific and technical advisory committees

Historically, the nation has been served in these relationships by the tradition of open inquiry that characterizes the science and engineering process.

Most scientists and engineers understand that complex policy decisions are not made on technical grounds alone. However, appropriate application of relevant scientific and technological factors leads to the most effective policy. If artificial constraints limit scientific input, the nation’s best scientists and engineers will feel less motivated to assess and interpret scientific information for decision-makers. Such constraints are not in the nation’s best interest.

Recognizing the need to ensure that science is used appropriately in the development and implementation of government policies, President Obama instructed the Office of Science and Technology Policy (OSTP) and the federal agencies in 2009 to develop guidelines to “guarantee scientific integrity throughout the executive branch.” 1 In December, 2010, OSTP issued guidance on the development of these policies including overarching principles, as well as specific rules on public communications, advisory committees, and the federal employee professional development.2 Executive branch agencies are now preparing specific polices.

Congress also faces challenges obtaining and utilizing unbiased, reliable scientific assessments. Since the 1995 demise of its Office of Technology Assessment, Congress has employed relatively few scientists or engineers to evaluate the technical dimensions of potential legislation. The Congressional Research Service and the Government Accountability Office have limited resources, but provide Congress with fast-response scientific analyses and recommendations. The National Research Council provides slower, but more comprehensive, assessments.

Despite recent White House guidance, federal government access to unbiased, adequate scientific insight and assessment remains a desirable goal. Further clarification of the rules and guidelines to assure scientific integrity is required to foster a true partnership between technical experts and policymakers.

Scientists and engineers have an obligation to provide comprehensive, transparent, unbiased, and understandable technical analyses. Policymakers have the responsibility to consider these analyses and any other relevant technical input in a comprehensive, transparent, and unbiased manner.

Recommendations

The American Chemical Society (ACS) strongly supports the use of insightful, comprehensive, scientific and engineering input to the development and evaluation of policy options. ACS also encourages scientific integrity policies, such as those recently instituted by the administration, that help the federal government obtain and integrate scientific assessments into policy development and implementation.³

The hallmarks of scientific integrity include incorporation of all relevant scientific information; succinct and understandable presentation; and thorough identification, quantification, and explanation of uncertainties. Attempts to alter or selectively use data or to bias analysis are unethical and do not serve the national interest. To clarify and strengthen the role of scientific insight and integrity in the development of public policy, ACS recommends that

• Federal agencies should consistently review and improve their ability to obtain and utilize unbiased scientific and technical input for policy development.
• Government policy analysts should ensure that scientific input draws from and references all relevant, peer-reviewed sources. Data used to develop federal policy, including unpublished or unreviewed content, should be publicly available and easily accessible.
• Quantitative scientific input with careful uncertainty and sensitivity analyses should be the norm. Conflicting results should be quantitatively assessed, evaluated, and reconciled by experts.
• Scientists and their institutions should not be burdened unreasonably by extensive or repetitive requests for information and explanation.
• Federally employed or funded scientists and engineers should be empowered to pursue professional development, present their unclassified research at appropriate technical symposia, and publish in peer-reviewed journals without interference. They also should be allowed to discuss their published, peer-reviewed research with the media and the public or comment publicly on policy options informed by their research and general technical knowledge.
• 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.
• Federal agencies should utilize scientific and technical advisory committees composed of qualified scientists and engineers to enhance and stimulate the efforts of their technical staff members. These committees should comprise an appropriate mix of technical expertise and breadth of experience. Their employers, professional or political affiliations, and prior policy positions should not preclude anyone from serving on advisory committees.
• Potential conflicts of interest among researchers and other experts involved in policy development and assessment should be handled transparently and fairly.
• Congress should strengthen its access to timely, transparent science, technology and policy analyses performed by qualified professionals.
• Congressional committees can and should seek direct testimony from technical experts on scientific and policy issues. However, hearings should not be used inappropriately to attack the research, motivation or integrity of witnesses.