Today, the U.S. Environmental Protection Agency (EPA) Office of Chemical Safety and Pollution Prevention (OCSPP) announced several actions to enhance scientific integrity, including establishing two internal science policy advisory councils, creating a new senior-level career position to serve as a science policy advisor to the Assistant Administrator, and making further improvements to policies and procedures.
In March of this year, OCSPP issued an office-wide memorandum that affirmed its commitment to scientific integrity as an essential and critical element in all work done in the office, a commitment also affirmed as one of Administrator Michael S. Regan’s first acts following his confirmation. The actions announced today represent the next steps in OCSPP’s commitment to strong science in the review of chemicals and pesticides and ensure these reviews adhere to the Biden-Harris Administration’s Executive Orders and other directives, including those on scientific integrity and regulatory review.
“Scientific integrity is the backbone of the work we do to ensure the safety of chemicals used in our everyday lives,” said Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Michal Freedhoff. “Strong, sound science underpins confidence in our decision-making among the public that we serve. Today’s announcements are the latest in a series of steps OCSPP is taking to reaffirm our commitment to scientific integrity and restore the public trust.”
Today’s announcement includes the following actions:
New OCSPP Science Policy Council and New Science Policy Advisor Position
OSCPP is forming a new internal advisory group, the OCSPP Science Policy Council, to provide advisory support and recommendations on science policy and scientific integrity issues that arise within its Office of Pollution Prevention and Toxics and Office of Pesticide Programs. The OCSPP Science Policy Council will be chaired by a science policy advisor, a newly created role that will report to the Assistant Administrator and provide guidance on emerging science policy and scientific integrity matters. The science policy advisor will also serve as the deputy scientific integrity official for OCSPP.
The OCSPP Science Policy Council will provide an advisory perspective on matters related to scientific integrity; identify scientific questions that are of broad interest within OCSPP for informal review and, as appropriate, recommend a process for further addressing them; and foster informal opportunities for scientific collaboration within OCSPP. Members chosen to address specific issues or questions will be selected based on their expertise, impartiality on the issue or question, and may include EPA experts outside of OCSPP. The group is not intended to replace or otherwise interfere with the Agency’s Scientific Integrity Policy, the Agency Scientific Integrity Official’s role, or the Inspector General’s role.
Strengthening New Chemical Safety Reviews
As part of OCSPP’s broader review of policies and procedures to ensure the program effectively implements the Biden-Harris Administration’s executive orders, other directives, and principles of scientific integrity, OCSPP’s New Chemicals Division (NCD) engaged in a top-to-bottom effort to catalogue, prioritize, and improve its standard operating procedures (SOPs), decision-making and record-keeping practices related to review and management of new chemicals under the Toxic Substances Control Act (TSCA). To date, NCD has inventoried and reviewed over 100 different SOPs, guidances and science policies, and prioritized those that NCD expects to be updated over the next year. Several policy changes have already been implemented, including stopping harmful new PFAS from entering the market and procedures to strengthen the review of new chemicals and ensure worker safety.
New Chemicals Advisory Committee
The New Chemicals Division has also formed the New Chemicals Advisory Committee (NCAC) that, similar to other long-standing internal advisory bodies within OCSPP, will serve as an advisory body to review both scientific and science policy issues related to new chemical submissions subject to TSCA. If differing opinions cannot be resolved through the human health risk assessment process improvements described below, the NCAC and OCSPP Science Policy Council could provide additional opportunities for further consideration.
The NCAC builds upon similarly structured advisory bodies within OCSPP and provides an opportunity for additional independent subject matter experts to participate in the discussion on scientific work products and cross cutting science policies. EPA’s Scientific Integrity Official was consulted in the development of the NCAC to ensure that the new committee adheres to the agency’s Scientific Integrity Policy. The operation of the NCAC will be reviewed periodically and, if needed, refined.
Human Health Risk Assessment Process Improvements
NCD solicited feedback from staff and implemented important changes to its process for reviewing and finalizing human health risk assessments. The new process provides additional opportunities for resolution of differing scientific opinions and invites input to the decision-making process to be provided by EPA subject matter experts outside of NCD.
Enhanced Recording-keeping Requirements
Proper documentation of decisions, and any differing scientific opinions of those decisions are a significant component of EPA’s Scientific Integrity Policy. We have implemented some changes to our procedures to ensure improved documentation of decisions, and are in the process of further review to identify additional improvements, if any, including for new chemicals human health risk assessments.
Workplace Climate Assessment
Last month, with the support of an independent contractor, OCSPP launched a workplace climate assessment of the NCD to capture feedback from employees and management about any potential workplace barriers and opportunities for organizational improvement. This effort will expand to other parts of OCSPP over the coming months.
OCSPP leadership will use the feedback collected through this effort to understand, evaluate, and, if necessary, make changes in OCSPP’s work practices and culture in order to promote collaboration and enhance the science that OCSPP uses in our program decision making.