As of September 30, 2015, EPA had received 81 allegations of a loss of scientific integrity since the Scientific Integrity Policy was published in 2012. Of those, 34 were active, 23 had been adjudicated; four were determined to not be scientific integrity issues; 17 were inactive; and three were reassigned.

Of the 81 allegations received as of the end of FY2015, the Agency received 37 within fiscal year 2015. This represents 0.5% of the total number of EPA employees and a slight decrease from the number received in FY2014 (which was 40).

Of the 37 allegations that were received in FY2015, 30 were made informally (where the person submitting the allegation prefers to not reveal their identity) and seven were made formally. In FY2014, 57.5% were informal; in FY2015, 81% were informal.

Of the 30 informal reports received in FY2015, only two came from outside the Agency. Seventeen came from EPA offices and programs and 11 came from regional offices. Of the seven formal allegations in FY2015, three came from outside the Agency, three from EPA offices and programs, and one from regional offices. There was a slight decrease in external allegations in FY2015, including both informal and formal allegations, compared to external allegations received in FY2014. There was a slight increase in internal allegations in FY2015 (32), compared to FY2014 (28).

The allegations received in FY2015 relate to several topics regarding scientific integrity. Eight allegations concern authorship and attribution; six concern suppression or delay of release of a scientific report or information; five concern scientific methods; five are conflicts of interest; three concern interference with science by a manager; and three are about data quality.

Allegations regarding authorship and attribution increased slightly in FY2015. EPA offices produce numerous authored scientific products every year. Some of these allegations concern whether an employee's contribution to a work product was significant and warrants a designation of authorship. The Scientific Integrity Official is prepared an Authorship Best Practices document, which released in FY2016.

Summary of Adjudicated Allegations

Thirteen allegations were adjudicated in FY2015. Eleven of these were substantiated and two were dismissed. Two of these adjudicated allegations concerned authorship disputes; two involved data quality; two concerned potential conflicts of interest; and two were concerns about the delayed release of scientific information. Summaries of the disposition of these allegations are below.

Adjudicated in FY 2015

1. Response to an Allegation of Interference by Manager with Science
   • Allegation:
     In a 2014 report, the Office of Inspector General (OIG) recommended that EPA's Scientific Integrity Official develop standard operating procedures detailing how staff should provide timely responses to requests for information by media, the public, and the scientific community. 
   • Summary:
     The Scientific Integrity Official and the Scientific Integrity Committee collaborated across the Agency to respond to the OIG recommendation. See Timeliness.
2. Response to an Allegation of Unsubstantiated EPA-Funded Report
   • Allegation:
     The complainant alleged that EPA contractors engaged in scientific misconduct in preparation of a research report. The complainant asked that EPA either retract the report or qualify the study's conclusions.
   • Summary:
     EPA qualified the report by attaching a statement explaining that the Agency does not have the data upon which the report's conclusions were based and that subsequent research did not reach the same conclusions as the report.
3. Response to an Allegation of Inappropriate Use of Data That are below the Laboratory's Reporting Limit
   • Allegation:
     The complainants, Quality Assurance (QA) staff and laboratory staff in a U.S. EPA Regional Laboratory, raised the following concerns:
     • A Project Manager requested raw data for a project, some of which were below the laboratory's reporting limit, for use in statistical analyses to evaluate "instrument noise." 
     • The QA staff's supervisor asked them to review a QA project plan (QAPP) developed by a Project Manager who also works for the supervisor. The QA staff were concerned that the supervisor had a conflict of interest by managing both the QA reviewers and the Project Manager.
   • Summary:
     A Scientific Integrity Review Panel met with all involved parties to discuss their different perspectives. The parties agreed to a process that will ensure that the data are used appropriately. Regarding the QA staff's concerns about potential conflicts of interest, the panel recommended that the Regional QA manager (who is not in the QA staff's organizational unit) review any QAPPs that are developed within the QA staff's unit.
4. Allegation of Flaws in an EPA-Funded Study
   • Allegation:
     The complainant alleged that an EPA-funded study was flawed and should not be cited as a basis for an EPA standard. 
   • Summary:
     The supporting materials did not reveal significant flaws in the study. Therefore, the allegation had no basis and was dismissed.
5. Pressure to Have Diverse FACA Panels
   • Allegation:
     The complainant said that Agency FACAs are under pressure to have diversified membership. The pressure could result in selection of panel members who may not have the strongest scientific qualifications. 
   • Summary:
     The Scientific Integrity Official directed outreach efforts at the appropriate parties.
6. Allegation of Interference by Manager with Science
   • Allegation:
     Management allegedly was interfering with a scientific assessment. The employee was pressured to change the conclusions of a risk assessment.
   • Summary:
     The matter was resolved when the manager agreed to stop interfering with the employee's scientific assessment.
7. Allegation of Interference by Manager with Science
   • Allegation:
     When new information came in after a peer review, management pressured staff to hold a new peer review that would include members with clear conflicts of interest.
   • Summary:
     The matter was resolved, because staff did not accept comments from any reviewers with conflicts of interest.
8. Manager Allegedly Delaying Publication
   • Allegation:
     Management approval of a scientific poster was delayed due to a disagreement about the appropriate methodology.
   • Summary:
     The employee and manager reached an agreement. The employee edited the poster and the manager approved it. 
9. Response to an Allegation of EPA Withholding Data and of EPA using Flawed Data
   • Allegation:
     The complainant alleged that EPA refused to release crucial scientific data that supported decision-making. The complainant also raised concerns about replication, reproducibility, and reanalysis of certain data sets.
   • Summary:
     EPA found that the Agency previously had provided the data that was in its possession and that these data had been reanalyzed through a rigorous process. In addition, the Agency noted that science is often most effectively advanced by new studies that attempt to demonstrate that the results of previous research did not happen by chance or occurred because of undetected confounders or bias.
10. Authorship Issue
    • Allegation:
      The complainant alleged that management had wrongfully removed the complainant's name from a conference presentation.
    • Summary:
      The complainant reported that the issue was resolved through communication with the manager.
11. Allegation of Interference by Manager with Publication
    • Allegation:
      Management asked an employee to stop sharing a newsletter with the public, although it had been shared with the public for many years.
    • Summary:
      The complainant reported that the issue was resolved through communication with the manager.
12. Allegation of Local Government Agency Publication Delay
    • Allegation:
      The complainant alleged that a local government was delaying the release of an EPA report.
    • Summary:
      The Scientific Integrity Official helped to expedite the release of the report.
13. Allegation of Authorship Issue
    • Allegation:
      This internal complaint concerned a dispute about authorship regarding three related projects.
    • Summary:
      The Scientific Integrity Official facilitated the resolution, with the parties negotiating an agreement

Additional Allegations that were Adjudicated in FY 2014

1. Request by 24 Scientists that Federal Agencies Remove Barriers that Prevent Agency Scientists from Sharing Their Expertise with the Public
   • Allegation:
     The complainant, a non-profit organization that represents scientists, conveyed the following concerns expressed by a group of scientists:
     • After a chemical spill, the U.S. Environmental Protection Agency and the Centers for Disease Control and Prevention failed to adequately respond to questions raised by the public and journalists;
     • These agencies' public affairs officers should not act as gatekeepers of information, especially during emergencies;
     • Policies should be updated to allow unfettered access to scientists with expertise that could help protect public health; and,
     • Other agencies, like National Oceanic and Atmospheric Administration, have shown that providing unfettered access to its scientists helps to build public faith and trust.
   • Summary:
     EPA's Associate Administrator for External Affairs responded that:
     • In this particular case, the state environmental agency had the lead for overseeing and coordinating response activities;
     • EPA had responded in a timely fashion to more than two dozen media outlets; and,
     • EPA is committed to transparency and to communicating with reporters.
2. Request that EPA Publish Conflict of Interest Waivers on its Website
   • Allegation:
     The complainant was concerned that EPA had not published information about Conflict of Interest Waivers granted to date for Science Advisory Board (SAB) panel members.
   • Summary:
     The Scientific Integrity Official responded that EPA had not granted any Conflict of Interest Waivers for SAB panel members to date. That is the reason that none are on the website. The allegation was dismissed.
3. Researchers Allegedly Omitted Data and Drew Erroneous Conclusions
   • Allegation:
     The complainant claimed that researchers engaged in scientific misconduct, omitting data and drawing erroneous conclusions about a scientific topic.
   • Summary:
     In response, the OIG issued a report on the subject in May 2014. According to the OIG report, EPA followed applicable regulations when conducting the study. The allegation was dismissed.
4. Request for EPA to Modify its New Guidance, "Conflict of Interest Review Process for Contractor-Managed Peer Reviews"
   • Allegation:
     The complainant, a non-profit organization, said that it welcomed the Agency's recently released guidance, "Conflict of Interest Review Process for Contractor-Managed Peer Reviews." However, it had concerns about its implementation and offered suggestions for improving the guidance.
   • Summary:
     The Agency responded that it would fully implement the process before assessing whether additional changes were needed.