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, I ME9g9fog Safeguarding the Future: Credible Science, Credible Decisions The Report o f the Expert Panel on the Role of Science at EPA to William K. Reilly Administrator U.S. Environmental Protection Agency March 1992

January 8,1992 Mr. William K. Reilly Administrator US. Environmental Protection Agency Washington, DC 20460 Dear Mr. Reilly: Earlier this year, you asked us to help identify how EPA can meet the goal of using sound science as the foundation for the Agency's policy and program decisions. You asked us to recommend ways to: (a) ensure that L1'A has up-to-date, objective scientific information for decisionmaking, (b) ensure that EPA's planning, resources, and leadership produce the knowledge base needed to achieve the Agency's new vision, (c) ensure that the research and scientific information needs of the programs and regions are met, and (d) enhance the stature of science within EPA and among the many constituencies with which EPA interacts. ToiOccomplish this task, we interviewed more than 30 individuals who have experience with these issues. We also held three public meetings that included individuals from various EPA offices and programs, other government agencies, industry, environmental groups, and other organizations. In addition, we requested written comments and received letters fmm more than 25 individuals, primarily from the EPA regional offices. We were impressed that so many people wished to help EPA find better ways to acquire and use sound scientific information. A number of consistent themes emerged from the discussions and comments. Everyone who spoke with the Panel agreed that EPA needs its own strong science base to carry out its mission effectively. At the same time, the Agency needs to make certain structural changes to improve the quality of its science and the way science is used in decisionmaking. In this report, we have developed these themes as a series of findings and recommendations about science at EPA. Included are suggestions for both short- and long-term measures to enhance the use of sound scientific and technical information throughout the Agency. We look forward to your serious consideration of these findings and recommendations and encourage you to take the necessary next steps as soon as possible. We appreciate the opportunity to be of assistance. Sincerely, Expert Panel on the Role of Science at EPA Raymond C. Loehr, Chair Bernard D. Goldstein Anil Nerode Paul G. Risser ii GUMM9

OUE999rog Contents Page TRANSMITTAL LETTER .................................................... ii EXEC[ TTIVE SUMMARY ..................................................... 1 THE EXPERT PANEL ....................................................... 10 BACKGROUND ...........................................................13 FINDINGS AND RECOMMENDATIONS I. THE MISSION AND DIRECTION OF EPA SCIENCE .................. 16 ~ II. THE QUALITY OF SCIENCE AT EPA ................................ 23 III. THE QUAI1'I'Y OF SCIENTISTS AT EPA ................................ 29 • IV. " HOW THE BUDGET PROCESS AFFECTS SCIENCE AT EPA ........... 33. V. HOW EPA USES SCIENCE IN DECISIONMAKING ................... 36 APPENDICES A. STRATEGIC DIRECTION FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY ................. r........................ 39 ,. : B. CHARGE TO THE EXPERT PANEL (MAY 22,1991) AND AFFILIATIONS OF PANEL MEMBERS ......................... 43 C. PERSONS INTERVIEWED BY THE EXPERT PANEL .................. 46 D. RECORD OF PUBLIC MEETING ATTENDANCE AND WRTITEN COMMENTS ....................................... 49 lII I

. ACKNOWL.EDGMENTS he Expert Panel acknowledges the support provided by EPA for this Tendeavor. Our thanks to Wendy Cleland-Hamnett, Jay Benforado, and Gail Robarge for their diligent efforts, which were criticall to the successful completion of this project. T09989pag iv

I Executive Summary BACKGROUND he mission of the U.S. Environmental Protection Agency (EPA) is to preserve Tand improve the quality of the environment, protect human health, and safeguard the productivity of natural resources on which all human activity depends. To achieve these aims, the Agency is committed to ensuring that "national efforts to reduce environmental risk are based on the best available scientific information communicated clearly to the public" (Strategic Direction for the U.S. Environmental Protection Agency: EPA...Preserving Our Future Today, 1991). EPA also is dedicated to "providing leadership in the nation's environmental science, research, and assessment efforts." This includes: • Gathering,and analyzing the data needed to evaluate environmental risks and trends, measure environmental results, and inform the choices of institutions and individuals throughout society. • Promoting and supporting innovative technological solutions to environmental problems. • Encouraging and conducting research that = r improves our understanding of health and ecological risks. • Providing objective, reliable, and understandable information that helps build trust in EPA's judgment and actions. • Sharing research findings and innovative technologies with other nations. In addition, EPA must be able to anticipate environmental problems caused by new and existing technologies and by societal changes. Executive Summary 1

BACKGROUND Several recent reports, including Future Risk: Research Strategies for the 1990s (1988, (CONTINUED) _ SAB-EC-88-040) and Reducing Risk: Setting Priorities and Strategies for Environmen- tal Protection (1990, SAB-EC-90-021), stressed that EPA must have a strong science base to accomplish these goals. Scientific knowledge has assumed an increasingly critical role as the environmental issues faced by the nation and the world grow in complexity and cut across all environmental media. The Agency must improve the scientific data and analyticall methodologies needed to make sound decisions; to set risk-based priorities for protecting health and the environment; to support a new emphasis on protecting the health of the nation's ecosystems (such as forests, lakes, and wetlands); and to contribute to internationall environmental efforts. THE EXPERT PANEL ON THE ROLE OF SCIENCE AT EPA In early 1991, EPA Administrator William K. Reilly established the Expert Panel qn the Role of Science at EPA as an independent advisory committee under the Federal Advisory Committee Act. The Expert Panel was charged with evaluating how EPA can meet the goal of using sound science as the foundation for Agency decisionmaking. The four members of the Panel were: • Dr. Raymond C. Loehr (Chair of the Panel), H.M. Alharthy Centennial (_'air in Civil Engineering, University of Texas. • Dr. Bernard D. Goldstein, Director, Environmental and Occupational Health Sciences Institute, Rutgers University and University of Medicine and Dentistry of New Jersey-Robert Wood Johnson Medical School. • Dr. Anil Nerode, Professor of Mathematics and Computer Science, Goldwin Smith Chair and Director, Mathematical Sciences Institute, Cornell University. • Dr. Paul G. Risser, Provost and Vice President for Academic Affairs, University of New Mexico. 2 Executive Summary

. APPROACH These individuals conduct extensive research programs and have had consider- able experience with various EPA programs. In addition, they have served on national committees evaluating scientific and technical programs. 0 ver a period of four months, the Panel held three public meetings and inter- viewed more than 30 individuals from EPA, other government agencies, industry, environmental groups, and other organizations. The Panel also requested written comments and received letters from more than 25 individuals, primarily from the EPA regional offices. The Panel performed no other independent evaluation of science at EPA; it did not review current research programs, visit EPA laboratories, or examine reports and data generated by EPA program and regional offices. Given the short time available for the Panel's review, the Panel determined that interviews and meet- ings ings with knowledgeable individuals within and outside EPA would be a more effective means of responding to its charge. The meetings and discussions focused on five topics that are crucial to obtaining and using sound science for credible decisions: • The mission and direction of EPA science. • The quality of science at EPA. z • The quality of scientists at EPA. • How the budget process affects science at EPA. • How EPA uses science in decisionmaking. The Panel defined science as encompassing a range of activities, including research and development, technical and regulatory support, monitoring, data collection, review and interpretation of technical studies, and assessments of health and environmental risk. The Panel intentionally included the science activities carried out in EPA program, policy, and regional offices, since such activities are part of the science EPA uses for decisionmaking. It also included the quantitative social sciences, such as economics, in addition to the physical, chemical, and biological sciences. . Executive Summary 3

AAJOR FINDINGS :VD ?COMMENDATIONS Overall, the Panel a ffirms that EPA needs its mvn strong science biase to provide the background required for effective environmental protection programs. T ~'+he Panel found that several consistent themes and concepts emerged from J the meetings, interviews, and letters. These are summarized in the findings and recommendations presented in subsequent sections of this report. Overall, the Panel affirms that EPA needs its own strong science base to provide the back- ground required for effective environmental protection programs. Currently, EPA science is of uneven quality, and the Agency's policies and regulations are frequently perceived as lacking a strong scientific foundation. To remedy these problems, the Panel recommends that EPA leadership undertake a deliberate and continuing effort to create the climate, culture, and incentives necessary to encourage superior science. The Panel recommends several specific structural changes to enable EPA to obtain and use the high-quality science it needs to realize its mission. These changes address science throughout the Agency, not only in the Office of Research and Development (ORD). The Panel's central findings and recommendations are listed below. 1 FINDING: EPA does not have a coherent science agenda and operational plan to guide scientific efforts throughout the Agency and support its focus on relatively high-risk environmental problems. .r RECOMMENDATION: The Agency has moved in the right direction with its new issue-based planning process. EPA should further develop this process with the overall goal of producing a broadly based, rational plan to acquire and use the best scientific information. This planning process should apply to science throughout the Agenty. Through this process, EPA can break from the past and shift toward the cross-media, anticipatory research needed to address complex, long-term, and global environmental problems. S6b£~E9~3~ i

, The Panel recommends that EPA leadership undertake a deliberate and continuing effort to create the climate, culture, and incentives necessary to encourage su perior science. 2 FINDING: EPA has not dearly conveyed to those outside or even inside the Agency its desire and commitment to make high-quality science a priority. RECOMMENDATION: EPA should send strong, clear signals to the scientific community and the public about its commitment to develop and use the best science for guidance and decisions. One immediate step to accomplish this could be the initiation of regular science briefings for the Administrator by EPA and non-EPA scientists on topics of critical concern to the Agency. 3 FINDING: The science advice function-that is, the process of ensuring that policy decisions are informed by a clear understanding of the relevant science- is not well defined or coherently organized within EPA. RECOMMENDATION: The Administrator should appoint a "science advisor" to ensure that credible scientific information for EPA guidance and decisions is available from both EPA scientists and the broader scientific community. The science advisor would implement a peer review and quality assurance program for all EPA's science-based products, improve the Agency's responsiveness to the science needs of EPA policymakers, play a key role in evaluating the professional activities of all scientists at EPA, and provide scientific advice to the Administrator. Executive Summary 5

MAJOR FINDINGS ` AND RECOMMENDATIONS (CONTINUED) LU9999fQg 4 FINDING: In many cases, appropriate science advice and information is not considered early or often enough in the decisionmaking process. RECOMMENDATION: EPA should take steps to ensure that science enters the decisionmaking process early and often. In regulatory development, EPA should implement a widely advertised, open process enabling the Agency to hear the scientific opinions of all parties. In addition, the Agency should analyze how it used science in developing one or more major regulations. The goal of this analysis would be to determine the type of sciuntific and technical information needed to ensure scientifically credible decisions, as well as the points in the regulatory process at which scientific input is most effective. The analysis should t*e into account the varying needs and decisionmaking processes of the different EPA program offices. - 5 FINDING: The development and nurturing of human resources are central to improving science at EPA. ! RECOMMENDATION: For ORD scientists, the Panel recommends continued attention to appropriate science and science management career tracks. For scientists in EPA program and regional offices, the Panel recommends establishing a science career track similar to that in place for those providing legal advice. The Agency also should enhance rotational opportunities that allow EPA scientists to participate in the broader scientific community and non-EPA scientists to work more dosely with EPA's science programs. 6 Executive Summary