Dr. John Holdren, Director
Office of Science and Technology Policy
Executive Office of the President
725 17th Street, N.W.
Washington, D.C. 20502

Dear Dr. Holdren:

Re: Scientists and Engineers for America Comments on the President’s March 9, 2009 Memorandum on Scientific Integrity

Scientists and Engineers for America, a non-profit dedicated to facilitating evidence-based decision making (http://www.SHARP.SEforA.org), appreciates the opportunity to comment on the Office of Science and Technology Policy’s responsibility for ensuring scientific integrity throughout the executive branch. We believe that a strong program of scientific integrity, carefully balancing an individual’s rights with employee responsibilities, is essential to ensuring that public policy is made using the best available scientific, technical, and engineering knowledge. Many of these principles are enunciated in our Scientists and Engineers Bill of Rights (http://SHARP.SEforA.org/bill-of-rights/), which is closely aligned with this OSTP statement.

With respect to principle A, that “the selection and retention of candidates for science and technology positions in the executive branch should be based on the candidate’s knowledge, credentials, experience, and integrity,” we urge the expansion of this principle to include appointment to Federal Advisory Committees. Selection of professionals in the executive branch and advisory committee members should be based on professional and academic credentials. This principle should be reflected in questions asked to candidates and other information gathered during the selection and retention processes. The credentials of those selected for service should be made easily available to the public.

Scientists and engineers in the executive branch should be involved in designing the rules and procedures for ensuring scientific integrity across agencies. Seeking input from government scientists and researchers will advance principle B, that “each agency should have appropriate rules and procedures to ensure the integrity of the scientific process within the agency,” and principle E, that “each agency should have in place procedures to identify and address instances in which the scientific process or the integrity of scientific and technological information may be compromised.” Government scientists should be able to speak freely about what rules and procedures would strengthen integrity, and their suggestions should inform policy. Administration-wide rules and procedures should be created, with individual agencies able to tailor rules and procedures if necessary to execute their mission.

Principle C of the Presidential Memorandum notes that “when scientific or technical information is considered in policy decisions, the information should be subject to well-established scientific processes, including peer review where appropriate . . .” To help ensure the accuracy of information considered in policy decisions, the OSTP recommendations should require that information considered be subject to well-established scientific processes that are evidence-based. Further, we believe that the idea in principle C that “each agency should appropriately and accurately reflect that information in complying with and applying relevant statutory standards” should explicitly include the idea that no government organization should knowingly distribute false or misleading information.

The Presidential Memorandum notes in principle D that, “except for information that is properly restricted from disclosure under procedures established in accordance with statute, regulation, Executive Order, or Presidential Memorandum, each agency should make available to the public the scientific or technological findings or conclusions considered or relied on in policy decisions.” The OSTP recommendations should address two elements in fulfilling this principle. First, the recommendations must aim to curb the restriction of documents from the public due to over-classification based on tenuous national security concerns (or other political concerns). The use of such pseudo-classifications as “Sensitive but Unclassified” and “Official Use Only” should be discouraged. These terms are ill-defined and subject to abuse. A clear, public, and transparent process must be used to make decisions about restricting public access to information for reasons of national security. There should be a process for challenging decisions and remedial measures in place to correct mistakes and abuses of the classification system.

Second, ensuring that scientific or technical findings or conclusions that do not directly involve national security make their way to the public in a timely fashion requires that scientists, technologists, and engineers conducting research or analysis with public funding be free of unreasonable restrictions in discussing and publishing their work, and the results of governmentally-funded research and analysis should be made open to the public without unreasonable delay. Establishing specific guidelines and principles in both areas are desirable. We encourage OSTP, working with NIST, to consider promulgating and regularly updating a Federal Information Processing Standard to make sure federal web sites are uniformly designed for ready up-to-date access as appropriate to federal scientific and technical information and databases. Scientists and researchers should be free to speak to the media about the results of their scientific work, and internal review processes should be expeditious. When acting as a private citizen, scientists and researchers should be unrestricted in discussing research and offering opinions on unclassified research, though it is reasonable to require explicit acknowledgment that the person is not representing his or her agency or its policies in such cases.

Finally, in terms of principle F, that “each agency should adopt additional procedures, including any appropriate whistleblower protections as are necessary,” we agree that no government researcher, scientists, or engineer should fear reprisals or intimidation because of the results of his or her research. In addition, protection must be extended to employees exposing what they believe to be manipulation of research and analysis for political or ideological reasons. Such employees should be protected from intimidation, retribution, or adverse personnel action resulting from the decision to speak out. They should be provided with ample opportunities for protected internal complaints to ombudspersons or hotlines.

The undersigned submit these comments for your consideration, and appreciate the prompt action of the administration in ensuring that public policy is made using the best available scientific, technical, and engineering knowledge.

Signed,

• Henry Kelly, Ph.D., Chair of Board of Directors
• James Turner, J.D., Treasurer of Board of Directors
• Brian Athey, Ph.D., Board member
• Lee Fikes, Board member
• Daniel Goroff, Ph.D., Board member
• Robert Hunter, Jr., Ph.D., Board member
• Burton Richter, Ph.D., Board member, Nobel Prize in Physics (1976)
• Robert M. White, Ph.D., Board member
• Susan Wood, Ph.D., Board member
• Peter Agre, M.D., Board of Advisors, Nobel Prize in Chemistry (2003)
• Sidney Altman, Ph.D., Board of Advisors, Nobel Prize in Chemistry (1989)
• Philip W. Anderson, Ph.D., Board of Advisors, Nobel Prize in Physics (1977)
• Nancy Bekavac, J.D., Board of Advisors
• Vinton Cerf, Ph.D., Board of Advisors, U.S. National Medal of Science, Presidential Medal of Freedom (1997)
• Melanie Cobb, Ph.D., Board of Advisors
• Johann Deisenhofer, Ph.D., Board of Advisors, Nobel Prize in Chemistry, (1988)
• John H. “Jack” Gibbons, Ph.D., Board of Advisors
• Lawrence Krauss, Ph.D., Board of Advisors
• Neal Lane, Ph.D., Board of Advisors
• Gilbert Omenn, M.D. Ph.D., Board of Advisors
• Douglas D. Osheroff, Ph.D., Board of Advisors, Nobel Prize in Physics (1996)
• Eugene Redmond, Jr., M.D., Board of Advisors
• Maxine Singer, Ph.D., Board of Advisors (US National Medal of Science, 1992)
• Lesley Stone, SEA, Executive Director
• Bernard Yu, SEA, Project Coordinator
• Theodore Iwashyna
• Miriam Quintal
• Carolynn Moore
• Farid Ben Amor
• Robert M. Suter
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• Jack A Mandelman, Ph.D.
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• Catherine Pries
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• Monica M Laronda
• Ben Dreidel
• John D. Bullough, Ph.D.
• Tara R. Gingerich, JD, MA
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• Michael Orchard, DVM, MD
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• Max Kaehn
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• Ian Evans
• Joel Trupin
• George Sai-Halasz, Ph.D.
• Damien Sullivan
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• John Urey
• Lin Westler
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• Dan Milutinovic
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• Richard C. Hover
• Robert Rochlin
• Sue Booth-Binczik, Ph.D.
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