Why we will choose public service over politics in the Pruitt EPA

Last fall, we learned of our nominations to serve on the Board of Scientific Counselors (BOSC) of the Environmental Protection Agency (EPA). We have each chosen to accept our appointment, despite a misguided and deeply troubling directive recently issued by EPA Administrator Scott Pruitt to bar experts currently receiving EPA grants from serving on any EPA advisory committees.

The BOSC is one of 22 federal advisory committees at EPA. Comprised of outside experts, the BOSC provides scientific advice and recommendations to the research arm of the agency, the Office of Research and Development (ORD).

Essentially, the job of the BOSC is to ensure that EPA’s research programs (focusing on air, water, community health, and chemical safety, among other areas) are supported by strong, high-quality science and work to fulfill the agency’s mission of protecting public health and the environment. Other committees that advise EPA include the Science Advisory Board (SAB), charged with peer-reviewing the science behind EPA’s policy decisions on environmental pollutants.

{mosads}Unfortunately, Pruitt’s directive undermines the BOSC and all other EPA advisory panels. His directive effectively purges independent university scientists from serving on advisory boards, simply because they receive EPA grants. Meanwhile, scientists employed or funded by private companies or trade associations — entities, unlike universities, that stand to directly gain or lose financially from agency actions — are not precluded from serving. We strongly oppose this directive.

Pruitt’s false premise is that scientists who receive EPA research support are biased; that they generate results that support EPA regulatory decisions so as to garner favor and further funding. It simply doesn’t work that way: EPA intentionally runs its extramural research program through its non-regulatory research arm ORD specifically to create separation from the agency’s program offices responsible for regulatory decisions.

The scientists at EPA involved in deciding which external scientists receive EPA research funding are not those making regulatory decisions. The great majority of EPA’s extramural research is funded through the Science to Achieve Results (STAR) grant program. STAR grant applicants undergo a highly competitive, peer-reviewed process to ensure their proposed research is scientifically sound and relevant. The end result of this rigorous review process is the funding of high-caliber research. Indeed, the STAR grant program has received significant praise by the National Academy of Sciences — the nation’s premier scientific body.

Rather than being excluded from service, EPA grantees should be viewed as strong candidates for EPA advisory committees. Because of the high standards for receiving EPA funding, these investigators represent the forefront of their fields — exactly the sort of experts well positioned to provide the necessary scientific advice to the EPA.

EPA has extensive conflict of interest requirements already in place to ensure potential conflicts of interests do not improperly affect the deliberations of the BOSC. Singling out investigators who receive EPA funding for exclusion is unfair and robs the agency of critical expertise. 

The scientific issues that the BOSC considers are challenging and important. For instance, our BOSC subcommittee will likely consider ORD’s work to develop new chemical testing methods. These methods hold the promise of being faster and cheaper while providing relevant and reliable safety data. For a decade, EPA scientists and others have been developing new molecular-, cell- and computer-based testing approaches to help fill pervasive data gaps on thousands of chemicals to help set priorities and take health-protective actions where needed. 

Eliminating input from independent university scientists who are leading experts in this field threatens the agency’s ability to ensure that these methods can be integrated appropriately and effectively in its chemical assessments.

Pruitt’s directive made our decision to serve on the BOSC a difficult one. We know of colleagues who have declined to serve in response to the directive, and we respect their decisions. Yet given the importance of ORD’s mission, we believe that it is vital for independent scientists representing the public interest to serve on the BOSC, particularly given the significant increase in the appointments of industry scientists to advisory committees and politically-appointed positions within the agency. For this reason, we have accepted our nominations. We take seriously the BOSC Charter’s emphasis on engaging a range of voices, as well as our responsibility to provide the best guidance possible to agency scientists to ensure their work in fact serves the public good. 

But let us be clear: Our service on this advisory board in no way reflects concurrence with Pruitt’s directive. In fact, we couldn’t disagree with it more and strongly urge Pruitt to rescind his directive.  

Dr. Juleen Lam is an Associate Research Scientist at the University of California, San Francisco where she specializes in environmental health issues, with a specific focus on vulnerable populations. 

Timothy Malloy is a professor at UCLA School of Law and the Fielding School of Public Health.

Dr. Jennifer McPartland is a senior scientist in the health program at Environmental Defense Fund where she works to reduce harmful chemical exposures through policy and market-based action.