CPR President Rena Steinzor and Policy Analyst Matt Shudtz submitted formal comments this week to the White House Office of Science and Technology Policy (OSTP) with policy recommendations for separating science from politics.

Back on March 9, President Obama issued a memorandum on scientific integrity, which outlined broad principles on the subject and requested that John Holdren, the director of OSTP, draw up a series of specific policy recommendations. CPR Member Scholars wrote a letter to Holdren with initial recommendations, and suggested opening the process to formal public comment. On April 27, the White House announced that they were doing just that.

The comments submitted by Steinzor and Shudtz on Wednesday give recommendations in response to each of the six broad principles that President Obama set out. Below is a summary of their recommendations.

Ensuring Selection and Retention of the Best-Qualified Candidates for Science & Technology Positions

• Agencies should improve the processes that they use to screen potential advisory committee members for conflicts of interest and bias. Waivers of conflicts of interest should be rare, rather than routine.

Ensuring the Integrity of the Scientific Process Through Agency Rules and Procedures

• Wherever possible, federal agencies should require all research used in regulatory decisionmaking to satisfy at least the same transparency and disclosure requirements as are currently applied to publicly funded research. That means requiring that the data supporting privately funded studies should be available both to agency scientists and the public.

Ensuring that Scientific and Technological Information is Reliable

• The President should direct EPA’s Office of Research and Development to review the procedures the agency uses to develop IRIS risk assessments, with an eye toward streamlining the process so as to encourage the swift development of assessments, particularly for substances that must be regulated under existing statutory authorities (e.g., the Clean Air Act and Safe Drinking Water Act).

Maximizing the Legitimate Public Release of Scientific and Technological Information Relied Upon by Agencies

• All of the information that goes into federal regulatory decisions would benefit from the disinfecting power of sunlight. Now that the Attorney General has re-established the “presumption of disclosure” under the Freedom of Information Act, federal agencies should consider three reforms to their confidential business information (CBI) policies: requiring upfront substantiation of all CBI claims; time limits (or “sunsets”) on CBI protections; and elimination of CBI protections for certain toxicological, eco-toxicological, and other physicochemical information.

Exposing Instances When Scientific or Technological Integrity Has Been Compromised

• In the interest of regulatory transparency and as a way to protect federal scientists, agencies should revise their recordkeeping policies to memorialize agency scientists’ pre-decisional findings. Agencies should explicitly exempt the products, analyses, and discussions of scientific research from the deliberative process privilege.

Ensuring Reliability of Science and Technology Through Whistleblower Protections and Other Procedures

• Agencies should establish enforceable ethics guidelines to protect federal scientists from political interference.