Given recent scientific misconduct (July is science scandal month [July 25 2011] post at The Prodigal Academic blog) and a very slow news month this August, I thought I’d take a look at scientific integrity in the US and in Canada.
First, here’s a little history. March 9, 2009 US President Barack Obama issued a Presidential Memorandum on Scientific Integrity (excerpted),
Science and the scientific process must inform and guide decisions of my Administration on a wide range of issues, including improvement of public health, protection of the environment, increased efficiency in the use of energy and other resources, mitigation of the threat of climate change, and protection of national security.
The public must be able to trust the science and scientific process informing public policy decisions. Political officials should not suppress or alter scientific or technological findings and conclusions. If scientific and technological information is developed and used by the Federal Government, it should ordinarily be made available to the public. To the extent permitted by law, there should be transparency in the preparation, identification, and use of scientific and technological information in policymaking. The selection of scientists and technology professionals for positions in the executive branch should be based on their scientific and technological knowledge, credentials, experience, and integrity.
December 17, 2010 John P. Holdren, Assistant to the President for Science and Technology and Director of the Office of Science and Technology Policy, issued his own memorandum requesting compliance with the President’s order (from the Dec. 17, 2010 posting on The White House blog),
Today, in response to the President’s request, I am issuing a Memorandum to the Heads of Departments and Agencies that provides further guidance to Executive Branch leaders as they implement Administration policies on scientific integrity. The new memorandum describes the minimum standards expected as departments and agencies craft scientific integrity rules appropriate for their particular missions and cultures, including a clear prohibition on political interference in scientific processes and expanded assurances of transparency. It requires that department and agency heads report to me on their progress toward completing those rules within 120 days.
Here’s my edited version (I removed fluff, i.e. material along these lines: scientific integrity is of utmost importance …) of the list Holdren provided,
- Ensure a culture of scientific integrity.
- Strengthen the actual and perceived credibility of Government research. Of particular importance are (a) ensuring that selection of candidates for scientific positions in executive branch is based primarily on their scientific and technological knowledge, credentials, experience, and integrity, (b) ensuring that data and research used to support policy decisions undergo independent peer review by qualified experts where feasibly and appropriate, and consistent with law, (c) setting clear standards governing conflicts, and (d) adopting appropriate whistleblower protections.
- Facilitate the free flow of scientific and technological information, consistent with privacy and classification standards. … Consistent with the Administration’s Open Government Initiative, agencies should expand and promote access to scientific and technological information by making it available online in open formats. Where appropriate, this should include data and models underlying regulatory proposals and policy decisions.
- Establish principles for conveying scientific and technological information to the public. … Agencies should communicate scientific and technological findings by including a clear explication of underlying assumptions; accurate contextualization of uncertainties; and a description of the probabilities associated with optimistic and pessimistic projections, including best-case and worst-case scenarios where appropriate.
- In response to media interview requests about the scientific and technological dimensions of their work, agencies will offer articulate and knowledgeable spokespersons who can, in an objective and nonpartisan fashion, describe and explain these dimension to the media and the American people.
- Federal scientists may speak to the media and the public about scientific and technological matters based on their official work, with appropriate coordination with their immediate supervisor and their public affairs office. In no circumstance may public affairs officers ask or direct Federal scientists to alter scientific findings.
- Mechanisms are in place to resolve disputes that arise from decisions to proceed or not to proceed with proposed interviews or other public information-related activities. …
(The sections on Federal Advisory Committees and professional development were less relevant to this posting, so I haven’t included them here.)
It seems to have taken the agencies a little longer than the 120 day deadline that John Holdren gave them but all (or many of the agencies) have complied according to an August 15, 2011 posting by David J. Hanson on the Chemical & Engineering News (C&EN) website,
OSTP director John P. Holdren issued the call for the policies on May 5 in response to a 2009 Presidential memorandum (C&EN, Jan. 10, page 28). [emphasis mine] The memorandum was a response to concerns about politicization of science during the George W. Bush Administration.
The submitted integrity plans include 14 draft policies and five final policies. The final policies are from the National Aeronautics & Space Administration, the Director of National Intelligences for the intelligence agencies, and the Departments of Commerce, Justice, and Interior.
Draft integrity policies are in hand from the Departments of Agriculture, Defense, Education, Energy, Homeland Security, Health & Human Services, Labor, and Transportation and from the National Oceanic & Atmospheric Administration, National Science Foundation, Environmental Protection Agency, Social Security Administrations, OSTP, and Veterans Administration.
The drafts still under review are from the Department of State, the Agency for International Development, and the National Institute of Standards & Technology.
The dates in this posting don’t match up with what I’ve found but it’s possible that the original deadline was moved to better accommodate the various reporting agencies. In any event, David Bruggeman at his Pasco Phronesis blog has commented on this initiative in a number of posts including this August 10, 2011 posting,
… I’m happy to see something out there at all, given the paltry public response from most of the government. Comments are open until September 6.Regrettably, the EPA [Environmental Protection Agency] policy falls into a trap that is all too common. The support of scientific integrity is all too often narrowly assumed to simply mean that agency (or agency-funded) scientists need to behave, and there will be consequences for demonstrated bad behavior.
But there is a serious problem of interference from non-scientific agency staff that would go beyond reasonable needs for crafting the public message.
David goes on to discuss a lack of clarity in this policy and in the Dept. of the Interior’s policy.
His August 11, 2011 posting notes the OSTP claims that 19 departments/agencies have submitted draft or final policies,
… Not only does the OSTP blog post not include draft or finalized policies submitted to their office, it fails to mention any timeframe for making them publicly available. Even more concerning, there is no mention of those policies that have been publicly released. That is, regrettably, consistent with past practice. While the progress report notes that OSTP will create a policy for its own activities, and that OSTP is working with the Office of Management and Budget on a policy for all of the Executive Office of the President, there’s no discussion of a government-wide policy.
In the last one of his recent series, the August 12, 2011 posting focuses on a Dept. of Commerce memo (Note: The US Dept. of Commerce includes the National Oceanic and Atmospheric Administration and the National Institute of Standards and Technology),
“This memorandum confirms that DAO 219-1 [a Commerce Department order concerning scientific communications] allows scientists to engage in oral fundamental research communications (based on their official work) with the media and the public without notification or prior approval to their supervisor or to the Office of Public Affairs. [emphasis David Bruggeman] Electronic communications with the media related to fundamental research that are the equivalent of a dialogue are considered to be oral communications; thus, prior approval is not required for scientist to engage in online discussions or email with the media about fundamental research, subject to restrictions on protected nonpublic information as set forth in 219-1.”
I find the exercise rather interesting especially in light of Margaret Munro’s July 27, 2011 article, Feds silence scientist over salmon study, for Postmedia,
Top bureaucrats in Ottawa have muzzled a leading fisheries scientist whose discovery could help explain why salmon stocks have been crashing off Canada’s West Coast, according to documents obtained by Postmedia News.
The documents show the Privy Council Office, which supports the Prime Minister’s Office, stopped Kristi Miller from talking about one of the most significant discoveries to come out of a federal fisheries lab in years.
Science, one of the world’s top research journals, published Miller’s findings in January. The journal considered the work so significant it notified “over 7,400″ journalists worldwide about Miller’s “Suffering Salmon” study.
The documents show major media outlets were soon lining up to speak with Miller, but the Privy Council Office said no to the interviews.
In a Twitter conversation with me, David Bruggeman did note that the Science paywall also acts as a kind of muzzle.
I was originally going to end the posting with that last paragraph but I made a discovery, quite by accident. Canada’s Tri-Agency Funding Councils opened a consultation with stakeholders on Ethics and Integrity for Institutions, Applicants, and Award Holders on August 15, 2011 which will run until September 30, 2011. (This differs somewhat from the US exercise which is solely focussed on science as practiced in various government agencies. The equivalent in Canada would be if Stephen Harper requested scientific integrity guidelines from the Ministries of Environment, Natural Resources, Health, Industry, etc.) From the NSERC Ethics and Integrity Guidelines page,
Upcoming Consultation on the Draft Tri-Agency Framework: Responsible Conduct of Research
The Canadian Institutes of Health Research (CIHR), the Social Sciences and Humanities Research Council of Canada (SSHRC), and NSERC (the tri-agencies) continue to work on improving their policy framework for research and scholarly integrity, and financial accountability. From August 15 to September 30, 2011, the three agencies are consulting with a wide range of stakeholders in the research community on the draft consultation document, Tri-Agency Framework: Responsible Conduct of Research.
I found the answers to these two questions in the FAQs particularly interesting,
- What are some of the new elements in this draft Framework?
The draft Framework introduces new elements, including the following:
A strengthened Tri-Agency Research Integrity Policy
The draft Framework includes a strengthened Tri-Agency Research Integrity Policy that clarifies the responsibilities of the researcher.
‘Umbrella’ approach to RCR
The draft Framework provides an overview of all applicable research policies, including those related to the ethical conduct of research involving humans and financial management, as well as research integrity. It also clarifies the roles and responsibilities of researchers, institutions and Agencies in responding to all types of alleged breaches of Agency policies, for example, misuse of funds, unethical conduct of research involving human participants or plagiarism.
A definition of a policy breach
The draft Framework clarifies what constitutes a breach of an Agency policy.
The draft Framework requires researchers to disclose, at the time of application, whether they have ever been found to have breached any Canadian or other research policies, regardless of the source of funds that supported the research and whether or not the findings originated in Canada or abroad.
The Agencies are currently seeking advice from privacy experts on the scope of the information to be requested.
The Agencies currently specify that institutional investigation committee membership must exclude those in conflict of interest. The draft Framework stipulates also that an investigation committee must include at least one member external to the Institution, and that an Agency may conduct its own review or compliance audit, or require the Institution to conduct an independent review/audit.
Timeliness of investigation
Currently, it is up to institutions to set timelines for investigations. The draft Framework states that inquiry and investigation reports are to be submitted to the relevant Agency within two and seven months, respectively, following receipt of the allegation by the institution.
- Who is being consulted?
The Agencies have targeted their consultation to individual researchers, post-secondary institutions and other eligible organizations that apply for and receive Agency funding.
As far as I can tell, there is no mention of ethical issues where the government has interfered in the dissemination of scientific information; it seems there is an assumption that almost all ethical misbehaviour is on that part of the individual researcher or a problem with an institution following policy. There is one section devoted breaches by institutions (all two paragraphs of it),
5 Breaches of Agency Policies by Institutions
In accordance with the MOU signed by the Agencies and each Institution, the Agencies require that each Institution complies with Agency policies as a condition of eligibility to apply for and administer Agency funds.
The process followed by the Agencies to address an allegation of a breach of an Agency policy by an Institution, and the recourse that the Agencies may exercise, commensurate with the severity of a confirmed breach, are outlined in the MOU.
My criticism of this is similar to the one that David Bruggeman made of the US policies in that the focus is primarily on the individual.
Tags: Barack Obama, Consultation on the Draft Tri-Agency Framework: Responsible Conduct of Research, David Bruggeman, David J. Hanson, Dept. of Fisheries and Oceans, ethics and integrity, John P. Holdren, Margaret Munro, Natural Science and Engineering Research Council, NIST, NOAA, NSERC, OSTP, Pasco Phronesis, Presidential Memorandum on Scientific Integrity, Privy Council Office, US Department of Commerce, US National Institute of Standards and Technology, US National Oceanic and Atmospheric Administration, White House Office of Science and Technology Policy