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Federal Agency Scientific Integrity Policies

In March 2009, the White House sent a memorandum to executive branch department and agency heads describing key elements of the Obama administration's plan to reform federal scientific integrity policy.

In December 2010, the Office of Science and Technology Policy (OSTP) issued a followup memorandum presenting more detailed guidelines for federal scientific integrity policies. (Our comments on the OSTP memo can be found here.) Agencies and departments were told to submit draft policies to OSTP by the beginning of August, but as of August 15, only a few drafts had been made public, and OSTP had not yet articulated a process for moving forward.

UCS has played a leading role in pressing the administration to fulfill its commitment, meeting with agencies to provide input and share information, offering a suite of resources for scientific integrity policy developers, and tracking scientific integrity progress.

Our comparative analysis of agency policies

As of March 2013, four years after the original White House memo, 22 departments and agencies have released either draft or final scientific integrity policies. UCS has prepared a comparative analysis of these policies, including detailed lists of each policy's strengths and weaknesses.

Clicking on an agency logo below will open to that agency's page in our analysis document.

Policies that actively promote and support a culture of scientific integrity:

Centers for Disease Control and Prevention

Final policy

Great policies on releasing and sharing data. Although it does not explicitly allow scientists the right of last review, it has many useful aspects to its media and communications policies.

Department of the Interior

Final policy | UCS analysis

One of the most detailed and comprehensive policies. It explicitly states that it applies to all employees – not just scientists!

Environmental Protection Agency

Draft policy | UCS comments | UCS analysis | Final policy

Breaks new ground in the areas of personal views exception and giving scientists the right of last review.

NASA

First OSTP report | Second OSTP report | Final policy

This is a list of existing policies with little narrative. Although there are good elements, agency scientists would have to spend hours to find and understand them.

National Oceanic and Atmospheric Administration (NOAA)

Draft policy | UCS comments | UCS analysis | Final policy | Procedural handbook

Excellent policy that is easy to access on the NOAA website; so long as the weaker Department of Commerce policy does not supersede.

National Science Foundation

Draft policy | UCS comments | UCS analysis | Final policy

The strongest media policy of all the agencies but missing some other key protections.

Policies that promote and support scientific integrity but need additional work to ensure that the policy stands the test of time:

Department of Commerce

Scientific integrity memoranda 

Cedes important details to its bureaus with an interest in science so don’t look here to see how the department will ensure the integrity of science.

Department of Homeland Security

Final policy

This policy is missing many key elements.

Department of State

Final policy

This policy fails to address many of the guidelines put forth in the December 9, 2010 memorandum and its communications policy is excessively restrictive.

Food and Drug Administration (FDA)

Final policy | Other FDA resources | UCS analysis

Principles are there but specific provisions and guidance are missing. ents, agency scientists would have to spend hours to find and understand them.

Marine Mammal Commission

Final policy

Commissions were not required to create scientific integrity policies. Although some key features are missing, everything in here is good.

Policies that do not make adequate commitments to scientific integrity:

Department of Defense

Final policy

This policy is excessively restrictive and vague, even given the nature of the Office.

Department of Education

Draft policy | UCS analysis and comments

This policy was released in draft form nearly a year ago and we could not locate a final policy or the draft policy on the department’s website. The draft lacked many crucial details.

Department of Energy

Policy statement on scientific integrity

This policy is less than three pages long and hence has many significant gaps. Does not fully embrace the principles in the OSTP guidance memo and has many additional missing elements.

Department of Health and Human Services

Final policy

HHS could have set the gold standard by calling on the depth of experience with scientific integrity at the NIH. But they did not.

Department of Justice

Draft policy

Very decentralized draft policy that could lead to problems for scientists and very limited commitments to transparency. No final policy could be found on the DOJ website.

Department of Labor

Draft policy | UCS analysis and comments | Final policy

The final policy is exactly the same as the draft policy in spite of a large response to a public comment period. Although the principles from the December 9, 2010 memorandum are repeated, there are many flaws, weaknesses, and gaps.

Department of Transportation

Final policy

This policy fails to address most of the guidelines put forth in the December 9, 2010 memorandum.

Department of Veterans Affairs

Draft policy | UCS analysis and comments

The final policy could not be located on their website. There was a public comment period but there is no evidence these comments were ever used to create a final policy. Many important features are missing from this draft.

Office of the Director of National Intelligence

Final policy

This policy could not be found on the ODNI website and had to be obtained through FOIA. The policy is excessively restrictive and vague, even given the nature of the Office.

USAID

Final policy

Implies that scientists must seek approval from public affairs before speaking to the media which could have a chilling effect on transparency.

USDA

Final policy | UCS comments

This policy has significant gaps and expired over a year and a half ago with no indication of plans for revisiting it.

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