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Quick Reaction Report:

EPA Must Take Steps to 

Implement Requirements of 

Its Scientific Integrity Policy

Report No. 13-P-0364 August 28, 2013

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL
Report Contributors: Eric Lewis 

Dwayne Crawford 

Alisha Chugh 

Chris Baughman 

Nyquana Manning

Abbreviations

EPA U.S. Environmental Protection Agency

OIG Office of the Inspector General

ORD Office of Research and Development

Hotline

To report fraud, waste, or abuse, contact us through one of the following methods:

email:

phone:

fax:

online:

OIG_Hotline@epa.gov

1-888-546-8740

202-566-2599

http://www.epa.gov/oig/hotline.htm

write: EPA Inspector General Hotline 

1200 Pennsylvania Avenue, NW

Mailcode 2431T

Washington, DC 20460
 

 13-P-0364

August 28, 2013

Why We Did This Review

During an Office of Inspector 

General review of a hotline 

complaint, we evaluated the 

U.S. Environmental Protection 

Agency’s progress in 

implementing certain 

requirements of its agencywide 

Scientific Integrity Policy. In 

March 2009, the President 

issued a memorandum to the 

heads of all executive 

departments and agencies for 

taking action to guarantee 

scientific integrity throughout the

executive branch. In the 

memorandum, the President 

instructed each agency to 

implement rules and procedures

for ensuring the integrity of the

scientific process within their

agency. The EPA enacted its

Scientific Integrity Policy in

February 2012. The policy

provides a framework intended

to ensure scientific integrity

throughout the EPA, and

describes the role of an

agencywide committee of 

scientific integrity officials to 

implement this policy.

This report addresses the 

following EPA Goal or 

Cross-Cutting Strategy: 

Advancing science, 

research, and technological 

innovation.

For further information, contact 

our Office of Congressional and 

Public Affairs at (202) 566-2391.

The full report is at:

www.epa.gov/oig/reports/2013/ 

20130828-13-P-0364.pdf

Quick Reaction Report: EPA Must Take 

Steps to Implement Requirements of Its 

Scientific Integrity Policy

 What We Found

Although an agencywide training program is required by the agency’s Scientific 

Integrity Policy, the EPA has not developed or implemented a program to

instruct the EPA’s employees on the requirements and standards of scientific

integrity. In addition, the EPA has not generated and made publicly available

an annual report on the status of scientific integrity within the agency as

required by the policy. The policy makes the EPA’s Scientific Integrity

Committee responsible for implementing these requirements. As a result of the

committee’s lack of progress in implementing these requirements, the EPA is 

less equipped to:

• Provide leadership for the agency on scientific integrity.

• Promote agency compliance with the Scientific Integrity Policy.

• Keep the agency’s senior leadership informed on and involved with

the agencywide status of scientific integrity.

• Detect violations of scientific integrity.

Planned Agency Corrective Actions

 What We Recommend and Agency Corrective Actions

We recommend that the EPA’s Deputy Administrator direct the Scientific

Integrity Committee to (1) develop and implement agencywide training on the

Scientific Integrity Policy in a manner that will minimize further delay in the EPA’s 

adherence to policy requirements, (2) complete and issue an annual report on 

the status of scientific integrity in the agency before its first formal review of the 

policy, and (3) provide the Deputy Administrator with a written plan describing

the action plan and milestones for implementing and completing the training and 

issuing the annual report.

We met with the EPA’s current interim scientific integrity official in July 2013 to 

discuss the findings and recommendations in our draft quick reaction report. In

response to our draft quick reaction report the EPA’s interim scientific integrity 

official included corrective actions with planned completion dates, or a statement 

that actions were complete, in response to all three OIG recommendations. The

corrective actions meet the intent of our recommendations. Recommendations 1 

and 2 are resolved with corrective actions underway. Recommendation 3 is 

completed and closed. No additional agency response to this report is required.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance
August 28, 2013

MEMORANDUM

SUBJECT: Quick Reaction Report: EPA Must Take Steps to Implement Requirements of Its 

Scientific Integrity Policy

Report No. 13-P-0364

FROM: Arthur A. Elkins Jr.

TO: Bob Perciasepe, Deputy Administrator

This is our report on the subject evaluation conducted by the Office of Inspector General of the 

U.S. Environmental Protection Agency. This report contains findings that describe the problems the OIG 

has identified and corrective actions the OIG recommends. This report represents the opinion of the OIG 

and does not necessarily represent the EPA position. 

Action Required

You are not required to provide a written response to this report because the corrective actions with 

estimated completion dates were provided in response to the draft quick reaction report. Please update 

the EPA Management Audit Tracking System as you complete the planned corrective actions. We will 

post this report to our website at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Assistant Inspector General 

for Program Evaluation Carolyn Copper at (202) 566-0829 or copper.carolyn@epa.gov, or Director for 

Special Program Reviews Eric Lewis at (202) 566-2664 or lewis.eric@epa.gov.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
13-P-0364 1

Purpose

During a separate Office of Inspector General review of a hotline complaint, 

we found conditions that caused us to assess the U.S. Environmental Protection 

Agency’s progress in implementing certain requirements of its Scientific Integrity

Policy. Specifically, we evaluated whether the EPA has:

• Developed and implemented training on scientific integrity for all the

EPA’s employees.

• Generated and made publicly available an annual report on the status of 

scientific integrity within the agency.

Background

On March 9, 2009, the President issued a memorandum to the heads of all 

executive departments and agencies for taking action to guarantee scientific 

integrity throughout the executive branch. In the memorandum, the President 

instructed each agency to implement rules and procedures for ensuring the 

integrity of the scientific process within their agency. Further, the President 

assigned the director of the Office of Science and Technology Policy the 

responsibility for conferring with the heads of executive departments and agencies 

and recommending a plan to achieve these goals.

In response to the President’s memorandum, the former EPA Administrator 

issued a memorandum in May 2009 to all the EPA’s employees notifying them 

of the President’s memorandum and that it provided important guideposts for

how the EPA should conduct and use science. The former Administrator’s

memorandum stated that the President’s memorandum provides the agency with 

a unique opportunity to further demonstrate a deep commitment to scientific

integrity in the pursuit of the agency’s vital mission of protecting human health 

and the environment. The former Administrator emphasized the agency should 

look for opportunities to strengthen existing policies and procedures that ensure

scientific integrity within the agency.

The director of the Office of Science and Technology Policy issued a 

memorandum in December 2010 to provide guidance to agencies to implement 

the Administration’s policies on scientific integrity. The director instructed 

agencies to develop policies that, among other things, do the following:

1. Ensure a culture of scientific integrity.

2. Strengthen the actual and perceived credibility of government research.

3. Facilitate the free flow of scientific and technological information, 

consistent with privacy and classification standards.

4. Establish principles for conveying scientific and technological information 

to the public.
13-P-0364 2

In accordance with these memorandums, the EPA enacted its Scientific Integrity 

Policy in February 2012. The policy provides a framework intended to ensure 

scientific integrity throughout the EPA. The EPA’s Scientific Integrity Policy also 

established a Scientific Integrity Committee, which is chaired by the scientific 

integrity official and consists of deputy scientific integrity officials from the 

agency’s program and regional offices. Under the Scientific Integrity Policy, the 

Scientific Integrity Committee is charged with implementing, reviewing and 

revising, as needed, the policy governing specific areas of scientific integrity. 

Specifically, the Scientific Integrity Committee is responsible for:

• Overseeing the development and implementation of training related to 

scientific integrity for all the EPA’s employees.

• Generating and making publicly available an annual report to the EPA 

science advisor on the status of scientific integrity within the agency. This 

report should highlight scientific integrity successes, identify areas for

improvement and develop a plan for addressing critical weaknesses, if 

any, in the agency’s program and regional offices.

According to the Scientific Integrity Policy, in advance of completing the annual 

report, the Scientific Integrity Committee is required to conduct an agencywide 

annual meeting on scientific integrity that will include the involvement of the 

EPA’s senior leadership, reports from offices and programs, and an opportunity 

for input from the EPA scientific community. The Scientific Integrity Committee 

is also expected to review the policy every 2 years for its effectiveness and 

adherence with applicable rules and regulations.

Prior Audit Coverage

On July 22, 2011, the OIG issued audit report “Office of Research and 

Development Should Increase Awareness of Scientific Integrity Policies,” 

Report No. 11-P-0386. This report addressed whether the EPA’s Office of 

Research and Development had controls to address scientific integrity and 

research misconduct, and whether those controls were effective. The EPA OIG 

found that ORD science staff was unaware of the EPA’s Principles of Scientific 

Integrity, which went into effect in March 2000. The EPA OIG also found that 

ORD had not updated the Principles of Scientific Integrity E-Training since

June 2005. Consequently, the EPA OIG made recommendations for improvement, 

including that the assistant administrator for ORD:

• Periodically test the effectiveness of controls to address scientific integrity 

and research misconduct.

 Continue working with the unions to update and implement the

Principles of Scientific Integrity E-Training. Changes to the course were

to include: (a) making the e-training mandatory for all ORD staff, 

(b) ensuring that the updated course contains real-life examples, and 
13-P-0364 3

(c) creating a system for linking to current contact information for

reporting instances of scientific integrity and research misconduct.

In response to the OIG report, ORD agreed with the recommendations and stated 

that the agency will make the Principles of Scientific Integrity E-Training

mandatory for scientific and technical staff and to update the course to contain reallife examples and links to current contact information for reporting instances of

scientific and research misconduct by July 2012. However, ORD noted that the 

agency was in the process of developing a new agencywide policy on scientific

integrity, had named an acting scientific integrity official, and would establish

deputy scientific integrity officials in each of the regions and offices.

The agency noted that these officials will serve as members of the EPA’s 

Scientific Integrity Committee, responsible for overseeing scientific integrity, and 

addressing allegations of scientific integrity violations. The committee would also 

be charged with standardizing the agency’s scientific integrity training and 

ensuring that the appropriate EPA staff complete the necessary training courses.

Scope and Methodology

We conducted our work from March to May 2013 in accordance with generally 

accepted government auditing standards issued by the Comptroller General of the 

United States. Those standards require that we plan and perform a review to 

obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based on 

our review objectives.

We reviewed the Scientific Integrity Policy to determine the agency’s Scientific 

Integrity Committee roles and responsibilities. We also reviewed the President’s 

March 2009 memorandum, the EPA Administrator’s May 2009 memorandum,

and the director of the Office of Science and Technology Policy’s December

2010 memorandum. We interviewed the EPA’s interim scientific integrity

official and staff from the Office of the Science Advisor regarding the status of

developing and implementing training for the EPA’s employees on the Scientific

Integrity Policy. We also interviewed these individuals to determine the status of

fulfilling other requirements for the Scientific Integrity Committee under the

policy.

Status of Implementing Training and Reporting Requirements of

Scientific Integrity Policy

We met with the agency’s interim scientific integrity official on March 14, 2013, 

to determine the status of developing and implementing training for the EPA’s 

employees on the Scientific Integrity Policy.

1 We found that the EPA has not 

 

1

In a May 8, 2013, memorandum from the Acting EPA Administrator, a new interim scientific integrity official was 

named. The interim scientific integrity official we met with on March 14, 2013, is now the former official.
13-P-0364 4

developed or implemented agencywide training on the Scientific Integrity Policy. 

Although the policy has been in place since February 2012, the former interim 

scientific integrity official reported that the Scientific Integrity Committee had not 

completed development and implementation of an agencywide training program. 

He noted that part of the delay in developing the training was due to the fact that 

they invited union participation. He further stated that it has taken quite a while for

the union to decide whether and how they wanted to participate in the training

development.

During our meeting with the former interim scientific integrity official, he could 

not provide any projected milestone dates or timeframes for when the committee

will complete this training requirement. On May 1, 2013, according to the audit 

follow-up coordinator for ORD and the agency’s Management Audit Tracking 

System, the estimated completion date for the agencywide training on the 

February 2012 Scientific Integrity Policy has been revised to December 31, 2013. 

However, neither the audit follow-up coordinator nor the Management Audit 

Tracking System entry indicated whether the agency’s Scientific Integrity 

Committee was involved in establishing the completion date for the agencywide 

training.

During our March 14, 2013, meeting, we also discovered that the EPA has not 

generated and made publicly available an annual report on the status of scientific 

integrity within the agency because the committee has not yet created it, as 

required by the Scientific Integrity Policy. The former interim scientific integrity

official could not provide any timeframe for when the committee will complete

the first annual report. The former interim scientific integrity official stated that 

the committee would have to develop and implement training on the Scientific

Integrity Policy for the EPA’s employees before they can complete the annual 

reporting requirement.

Conclusion

As a result of the Scientific Integrity Committee’s lack of progress in implementing

the training and annual reporting requirements, the committee cannot fully determine

the EPA employees’ compliance with the agency’s Scientific Integrity Policy. In

addition, required determinations of the effectiveness of the policy and the status of

scientific integrity in the EPA are lacking and will continue to be delayed until the

policy requirements are implemented. By implementing these key requirements in its 

Scientific Integrity Policy, the EPA would be acting in accordance with the

President’s 2009 memorandum for ensuring the integrity of the scientific process and

further demonstrating the EPA’s commitment to scientific integrity in the pursuit of

the agency’s vital mission of protecting human health and the environment.
13-P-0364 5

Recommendations

We recommend that the EPA’s Deputy Administrator direct the Scientific

Integrity Committee to:

1. Develop and implement agencywide training on the Scientific Integrity 

Policy in a manner that will minimize further delay in the EPA’s 

adherence to policy requirements.

2. Complete and issue an annual report on the status of scientific integrity in 

the EPA before its first formal review of the policy.

3. Provide the Deputy Administrator with a written plan describing the action 

plan and milestones for implementing and completing the training and 

issuing the annual report.

Agency Response to Draft Quick Reaction Report and OIG Evaluation

The current interim scientific integrity official responded to our draft quick reaction 

report on June 14, 2013 (appendix A). The official commented that our draft quick 

reaction report lacked recognition of what has been done thus far to implement the 

Scientific Integrity Policy within the agency. During a follow-up meeting to discuss 

the official’s comments, we informed the official that our findings and 

recommendations are based on information we obtained from the former interim 

scientific integrity official during a meeting held in March 2013 and our review of 

the policy. We informed the current official that the former official reviewed our

draft quick reaction report and did not dispute the facts we reported. 

We met with the EPA’s current interim scientific integrity official in July 2013 to 

discuss the findings and recommendations in our draft quick reaction report. The 

current interim scientific integrity official’s response to our draft quick reaction 

report provided updated information on the status of implementing training and 

reporting requirements under the Scientific Integrity Policy. Specifically, the 

response included corrective actions with planned completion dates or indication 

that the recommended action was completed. Specifically:

The Scientific Integrity Committee plans to finalize the scientific integrity 

training module by December 31, 2013, and make it available through 

Skillport (i.e., the agency’s e-learning training portal). According to the 

current interim scientific integrity official, this date was coordinated and 

approved by the committee.

The committee has reviewed an outline for the annual report on scientific 

integrity and, after receiving input at the annual meeting on June 25, 2013, 

plans to finalize the report by September 30, 2013.
13-P-0364 6

The committee has outlined a plan for moving forward with completing the 

training and issuing the annual report. The Deputy Administrator has been 

briefed, provided input and agreed with the plan presented to him. The 

deputy director for the EPA’s Office of the Science Advisor confirmed that 

the briefing to the Deputy Administrator, which occurred on June 7, 2013, 

covered progress on implementing the Scientific Integrity Policy and related 

matters. 

In accordance with EPA Manual 2750, the OIG has determined that the corrective

actions meet the intent of our recommendations. Recommendations 1 and 2 are

considered resolved with corrective actions underway. Recommendation 3 is 

completed and considered closed. No additional response to this report is required. 

However, the involved agency office should update the EPA Management Audit 

Tracking System as planned corrective actions are completed, and notify the OIG if 

there is a significant change in the agreed-to corrective actions.

Our detailed responses to agency comments on the draft quick reaction report are 

included in appendix B. Additional attachments provided with the agency’s signed 

and dated comments can be located at http://www.epa.gov/oig. 
13-P-0364 7

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 5 Direct the Scientific Integrity Committee to develop 

and implement agencywide training on the

Scientific Integrity Policy in a manner that will 

minimize further delay in the EPA’s adherence to 

policy requirements.

O EPA Deputy Administrator 12/31/2013

2 5 Direct the Scientific Integrity Committee to 

complete and issue an annual report on the status

of scientific integrity in the EPA before its first 

formal review of the policy. 

O EPA Deputy Administrator 09/30/2013

3 5 Direct the Scientific Integrity Committee to provide

the Deputy Administrator with a written plan 

describing the action plan and milestones for

implementing and completing the training and 

issuing the annual report.

C EPA Deputy Administrator 06/07/2013

1 O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is unresolved with resolution efforts in progress
13-P-0364 8

Appendix A

Agency’s June 13, 2013 Comments on the OIG’s 

Draft Quick Reaction Report

MEMORANDUM

SUBJECT: Response to Office of Inspector General’s Draft Report Entitled Quick Reaction 

Report: The EPA Must Take Steps to Implement Requirements of its Scientific 

Integrity Policy

FROM: Glenn Paulson, Ph.D.

Interim Scientific Integrity Official for EPA

TO: Arthur A. Elkins, Jr.

Inspector General

Thank you for the opportunity to provide comments and additional information on this Draft 

Quick Reaction Report. In addition to general comments on the conclusions and 

recommendations, technical comments are provided in Attachment 1. 

I have personally met with the Office of Inspector General management several times to develop 

coordination procedures on actions related to allegations of scientific misconduct and therefore I 

am surprised by the tone and method that is being used for this draft report. During our last 

meeting, I suggested that OIG attend the Agency’s Scientific Integrity annual meeting scheduled 

for June 25. You have already received and accepted a formal invitation to this meeting. Further, 

the hot line call mentioned in this report and the report’s recommendations do not appear to me 

to have any connection with each other. 

OVERALL COMMENTS

In February 2012, the EPA published a Scientific Integrity Policy that built on our long history 

of scientific safeguards to further ensure that sound science drives agency decision-making. The 

EPA’s ability to fulfill its mission to safeguard human health and protect the environment 

depends on sound scientific analyses, and the Agency remains committed to scientific integrity. 

When dealing with science, it is the responsibility of every EPA employee to conduct, utilize, 

and communicate science with honesty, integrity, and transparency, both within and outside the 

agency. When Bob Perciascepe (then Deputy Administrator) announced the Scientific Integrity 

Policy in his “All EPA Employees” memorandum dated February 16, 2012, he stated that the 

Policy became effective immediately. Each employee received this email, demonstrating the 

Policy’s importance.

The draft report demonstrates both a lack of clear understanding of the Policy and also any 

recognition of what has been done thus far to implement it at the Agency. For example, the draft 

does not acknowledge that the Policy not only incorporates but goes well beyond the OSTP 
13-P-0364 9

guidance, and in addition clearly demonstrates the EPA’s commitment to Scientific Integrity 

through a training element, as well as an annual meeting and report. 

The draft report’s core concern is that the development of training and the generation of an 

annual report have not been completed. The draft report does not acknowledge that, in fact, 

work on both is well advanced, and substantial efforts have been devoted as necessary to bring 

that work to its current status. The draft report fails to acknowledge the ongoing work that the 

Scientific Integrity Committee is undertaking to ensure consistent implementation of the Policy. 

The Interim Scientific Integrity Official has, in addition to leading the Committee, addressed 

several allegations of scientific misconduct that have been reported by outside entities.

These cases have been resolved, and also discussed with the OIG. Finally, we have also been 

working with the OIG to develop procedures to ensure coordination on allegations of scientific 

misconduct or other violations of the Scientific Integrity Policy (See Attachment 2). The draft 

Quick Reaction Report leaves the erroneous impression that there is little work being done on 

scientific integrity issues. While completion of the training module and the annual report are 

important, these are only two of the activities currently underway, and they do not impede 

agency managers and employees from complying with the Policy or detecting and reporting 

violations of the Policy. 

As identified in this response, the draft report contains substantial misstatements. Since the work 

outlined in the draft report’s Recommendations is already well advanced, finalization of the OIG 

draft report would not contribute to effective completion of that work. By failing to 

acknowledge these activities and arriving in the midst of their completion, the draft Quick 

Reaction Report, if made final, would be superfluous. It would, however, further delay the work 

of the Scientific Integrity Committee and staff in implementation of the Policy. To respond to 

this draft, OSA’s scientific integrity staff has already been diverted away from developing the 

training, planning the annual meeting, and gathering information for the annual report.

AGENCY RESPONSE TO RECOMMENDATIONS

The draft report recommends that the EPA’s Deputy Administrator direct the Scientific Integrity 

Committee to (1) develop and implement agencywide training on the Scientific Integrity Policy

in a manner that will minimize delay in the EPA’s adherence to policy requirements, (2) 

complete and issue an annual report on the status of scientific integrity in the agency before its 

first formal review of the policy, and (3) provide the Deputy Administrator with a written plan 

describing the actions and milestones for implementing and completing the training and issuing 

the annual report.

The draft report claims that the Scientific Integrity Committee’s lack of progress in 

implementing the requirements of the Policy is resulting in the EPA being less equipped to 

provide leadership for the Agency on Scientific Integrity, promote compliance with the Policy, 

keep the Agency’s senior leadership informed on and involved with the agencywide status of 

scientific integrity, and detect violations of scientific integrity. 
13-P-0364 10

Contrary to this claim, the Committee, comprised of senior management officials from across the 

agency, meets regularly to discuss elements of the Policy and enhance consistency across the 

Agency. These elements include development of a training module on the Scientific Integrity 

Policy, options for management certification of compliance with the policy, coordination

procedures for the Scientific Integrity Official and the OIG, and the format for the annual 

meeting and annual report. By meeting regularly to discuss scientific integrity, the Committee 

provides a critical cross-agency resource for conveying information and providing leadership on 

the Policy. Further, the Deputy Administrator has provided guidance and is already directly 

engaged with the Scientific Integrity Policy’s implementation. 

The training module development, while important, cannot be used as a surrogate for 

demonstrating Policy implementation. In compliance with an earlier recommendation from the 

OIG to work with the unions in developing scientific integrity principles training (“Office of 

Research and Development Should Increase Awareness of Scientific Integrity Policies,” Report 

No. 11-P-0386), over a period of several months the Committee diligently urged the unions to 

recruit volunteers to participate in training development.

In a letter from the unions dated last November 21, 2012, the unions acknowledge that the EPA 

reached out to them for their participation (Attachment 3). When no representatives were 

named, Mary Greene, Deputy Director of the Office of the Science Advisor, responded back to 

them on January 9, 2013, again requesting participation (Attachment 4.) Union representative 

names were finally provided on May 3, 2013, and the first full workgroup meeting has already 

taken place. At the same time, the Committee has continued to develop the training module on 

the Scientific Integrity Policy. As reported to the OIG on April 3, 2013, the Committee plans to 

finalize the scientific integrity training module by December 31, 2013 and make it available 

through Skillport. The Quick Reaction Report implies that no progress has been made on the 

training development action; this is simply not true.

In a memorandum to the Scientific Integrity Committee dated May 8, 2013, the Acting 

Administrator reiterated his commitment to scientific integrity and provided thoughts to the 

Committee on the organization of the annual meeting on scientific integrity and the content of 

the annual report. He requested that the Committee complete the annual report by the end of 

Fiscal Year 2013. A copy of his memorandum is found at Attachment 5. The Scientific 

Integrity Committee has reviewed an outline for the annual report on scientific integrity and, 

after receiving input at the upcoming annual meeting on June 25, plans to finalize the report by 

September 30, 2013.

The third recommendation, to provide the Deputy Administrator with a written plan for 

completing the training and issuing the annual report, is not needed as we have already outlined 

the path forward, and the Deputy Administrator has been briefed, provided input, and agreed 

with the plan presented to him.

As required by the EPA Order 2750, the agency’s written response to a final report would 

address any recommendations that may be included at that time. We would consider any 

recommendations on their merits and, if applicable, provide a corrective action plan and/or offer 

alternative solutions to the report’s recommendations. 
13-P-0364 11

I request that you withdraw the draft report at this time. In my view, an appropriate time to 

review the EPA’s implementation of the Policy would be after the first annual report is issued 

and the first cycle of training is at least well underway, if not completed. 

CONTACT INFORMATION 

If your staff has any questions, please contact Martha Otto, Scientific Integrity Staff, Office of 

the Science Advisor, at (202) 564-2782 or otto.martha@epa.gov. 

Attachments 

cc: Bob Perciasepe, Acting Administrator
13-P-0364 12

Appendix B

OIG Responses to Agency’s Comments on Draft Quick Reaction Report 

General Comments

“I have personally met with the Office of Inspector General management several times to 

develop coordination procedures on actions related to allegations of scientific misconduct and 

therefore I am surprised by the tone and method that is being used for this draft report.”

“During our last meeting, I suggested that OIG attend the Agency's Scientific Integrity annual 

meeting scheduled for June 25. You have already received and accepted a formal invitation to 

this meeting.”

“Further, the hot line call mentioned in this report and the report's recommendations do not 

appear to me to have any connection with each other.”

Overall Comments

“The draft report demonstrates both a lack of clear understanding of the Policy and also any 

recognition of what has been done thus far to implement it at the Agency.” The Quick Reaction 

OIG Response #2: The agency’s plans to hold a Scientific Integrity annual meeting was

announced in a May 8 memo issued by the Acting EPA Administrator, which occurred 

after OIG staff started its work to issue the draft quick reaction report. While we did 

participate in that meeting, that type of meeting cannot be a substitute for conveying 

OIG findings on matters of scientific integrity or draft report findings that have not been 

through the OIG’s quality assurance review process.

OIG Response #1: We understand those coordination procedures. However, those 

matters pertain to how our offices will coordinate when scientific misconduct 

allegations or scientific integrity allegations are received. Those coordination 

procedures do not apply to how OIG coordinates with agency counterparts when we 

conduct audits and evaluations of agency activities and programs. The manual that 

covers how we coordinate in those activities is EPA Manual 2750, for which the audit 

liaison is the point of contact. We believe the tone of our draft quick reaction report

was balanced and fair.

OIG Response #3: The information on the hotline is provided solely for context. We 

received a hotline allegation that was not framed as a scientific integrity allegation.

This other report is in draft and therefore we are limited in our ability to provide further 

details at this time.
13-P-0364 13

Report implies that no progress has been made on the training development action; this is simply 

not true.”

“I request that you withdraw the draft report at this time. In my view, an appropriate time to 

review the EPA's implementation of the Policy would be after the first annual report is issued 

and the first cycle of training is at least well underway, if not completed.”

Technical Comments

“Page 3, in the first sentence of the first paragraph, the draft report states that, "In response, the 

agency agreed to make the Principles of Scientific Integrity E Training mandatory for scientific 

and technical staff and to update the course ... " In fact, the Office of Research and Development, 

not the agency, provided those responses to the OIG recommendations.”

“Page 4, in the first full paragraph, the draft report states that, "During our meeting with the 

interim scientific integrity official, he could not provide any projected milestone dates or 

timeframes for when the committee will complete this training requirement." This is factually 

incorrect. The interim scientific integrity official said that the Committee should finish the 

training this year.”

OIG Response #4: We have read the policy and understand it. Our findings are based on 

information we obtained from the (now former) interim scientific integrity official in early 

March 2013 and our review of the policy. The former interim scientific integrity official 

reviewed the draft quick reaction report and did not dispute the facts we reported. 

However, in response to our draft quick reaction report, the current interim scientific 

integrity official provided the OIG with new information on correctives actions and 

milestone dates regarding the agency’ progress on the development and implementation of 

the training and annual reporting schedule. This information is included under the section 

entitled “Agency Response to Draft Quick Reaction Report and OIG Evaluation.”

.

OIG Response #5: The OIG does not plan to withdraw its report. Rather, as the standard 

OIG practice, when the agency provides new information in response to a draft OIG report, 

that information will be included in OIG’s final report so that we are reporting the best 

available information we have. In this case, the information on corrective actions and 

milestones dates that the current interim scientific integrity chairman has reported in 

response to our report is included under the section entitled “Agency Response to Draft

Quick Reaction Report and OIG Evaluation.”

OIG Response #6: The OIG checked the referenced audit report and confirmed this 

fact. The final report now states this action was taken by ORD.
13-P-0364 14

“Page 4, in the first full paragraph, the draft report states that, "On May l, 2013, according to the 

Audit Follow-up Coordinator for ORD and the agency's Management Audit Tracking System, 

the estimated completion date for the agencywide training on the February 2012 Scientific 

Integrity Policy has been revised to December 31, 2013. However, neither the audit follow-up 

coordinator nor the Management Audit Tracking System entry indicated whether the agency's 

Scientific Integrity Committee was involved in establishing the completion date for the 

agencywide training."The date approved by the Scientific Integrity Committee was coordinated 

with ORD's Audit Coordinator. This statement is factually incorrect and needs to be deleted.”

“Page 4, in the second full paragraph, last sentence, the draft report says that, "The interim 

scientific integrity official stated that the committee would have to develop and implement 

training on the Scientific lntegrity Policy for the EPA's employees before they can complete the 

annual reporting requirement." This is factually incorrect.”

“When asked whether the Committee had completed the annual report, the interim scientific 

integrity official replied that the Committee was discussing the format for the annual report. He 

did not state that the annual report would have to wait for training development.”

OIG Response #7: The former interim scientific integrity official never stated to the 

OIG that the training would be completed in calendar year 2013. Rather, the former 

interim scientific integrity official stated that a timeline for completion of the training 

program was hard to determine (at the time of our March 2013 meeting) since the 

committee was still waiting to see how the union intended to participate. The former 

interim scientific integrity official reviewed OIG’s draft quick reaction report and did 

not dispute the facts in it, including information obtained in interviews with the former 

official.

OIG Response #8: We communicated with the audit follow-up coordinator and the 

coordinator did not state that the Scientific Integrity Committee established the 

December 2013 date for completion of the agencywide training. We also reviewed 

the Management Audit Tracking System records and found no evidence that the 

December 2013 date was coordinated through the Scientific Integrity Committee. 

However, based on the information provided by the current interim scientific 

integrity official in response to our draft quick reaction report, we note in this report 

that the date was coordinated and approved by the Scientific Integrity Committee.

This reference is included under the first bullet of the section entitled “Agency 

Response to Draft Quick Reaction Report and OIG Evaluation.”

OIG Response #9: The former interim scientific integrity official 

reviewed OIG’s draft quick reaction report and did not dispute the facts in 

it, including information obtained in interviews with the former official. 
13-P-0364 15

Comments on Recommendations

We recommend that the EPA’s Deputy Administrator direct the Scientific

Integrity Committee to:

1. Develop and implement agencywide training on the Scientific Integrity Policy in a

manner that will minimize further delay in the EPA’s adherence to policy

requirements.

Comment – “In a letter from the unions dated last November 21, 2012, the unions acknowledge 

that the EPA reached out to them for their participation (Attachment 3). When no representatives 

were named, the Deputy Director of the Office of the Science Advisor responded back to them 

on January 9, 2013, again requesting participation (Attachment4.) 'Union representative names 

were finally provided on May 3, 2013, and the first full workgroup meeting has already taken 

place. At the same time, the Committee has continued to develop the training module on the 

Scientific Integrity Policy. As reported to the OIG on April 3, 2013, the Committee plans to 

finalize the scientific integrity training module by December 31, 2013 and make it available 

through skill port.” 

2. Complete and issue an annual report on the status of scientific integrity in the EPA 

before its first formal review of the policy.

Comment – “In a memorandum to the Scientific Integrity Committee dated May 8, 2013, the 

Acting Administrator reiterated his commitment to scientific integrity and provided thoughts to 

the Committee on the organization of the annual meeting on scientific integrity and the content 

of the annual report. He requested that the Committee complete the annual report by the end of 

Fiscal Year 2013. A copy of his memorandum is found at Attachment 5. The Scientific 

Integrity Committee has reviewed an outline for the annual report on scientific integrity and, 

after receiving input at the upcoming annual meeting on June 25, plans to finalize the report by 

September 30, 2013.”

OIG Response #10: Our findings are based on information we obtained from 

the (now former) interim scientific integrity official in early March 2013, during 

which we were not informed of the established date of December 31, 2013, for 

finalizing the scientific integrity training module. Nonetheless, the agency’s 

comments in response to our draft quick reaction report are responsive to 

recommendation 1. The agency’s reported actions include a plan and a date for 

corrective action. Therefore, the OIG considers this recommendation to be 

resolved. 

OIG Response #11: The agency’s comments are responsive to 

recommendation 2. The agency’s reported actions include a plan and a date for 

corrective action. Therefore, the OIG considers this recommendation to be 

resolved. 
13-P-0364 16

3. Provide the Deputy Administrator with a written plan describing the action plan and 

milestones for implementing and completing the training and issuing the annual report.

Comment – “The third recommendation, to provide the Deputy Administrator with a written 

plan for completing the training and issuing the annual report, is not needed as we have already 

outlined the path forward, and the Deputy Administrator has been briefed, provided input, and 

agreed with the plan presented to him.”

OIG Response #12: The agency’s comments are responsive to 

recommendation 3. The agency’s reported actions included a plan and a date for 

corrective action. Therefore, the OIG considers this corrective action to be 

completed and the recommendation to be closed.
13-P-0364 17

Appendix C

Distribution

Office of the Administrator

Deputy Administrator

EPA Science Advisor

Agency Follow-Up Official (CFO)

Agency Follow-Up Coordinator

General Counsel

Associate Administrator for Congressional and Intergovernmental Relations

Associate Administrator for External Affairs and Environmental Education

Principal Deputy Assistant Administrator, Office of Research and Development 

Deputy Assistant Administrator, Office of Research and Development 

Audit Follow-Up Coordinator, Office of Research and Development