Scientific Integrity: EPA's Efforts to Enhance the Credibility and Transparency of Its Scientific Processes
Published: 2009-06-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Environmental Protection Agency's (EPA) ability to effectively implement its mission of protecting public health and the environment relies largely on the integrity and transparency of (1) its assessments of the potential human health effects of exposure to chemicals and (2) its federal advisory committees, which are to provide independent, expert reviews of EPA's scientific work, among other functions. EPA's Integrated Risk Information System (IRIS) program is critical in developing the agency's scientific positions on the potential health effects of exposure to toxic chemicals. These positions, used as a basis for environmental risk management decisions by EPA and others, are maintained in IRIS' database of more than 540 chemical assessments. Since 2001, GAO has issued a number of reports addressing the importance of integrity and transparency to EPA's chemical assessments and to EPA's federal advisory committees. GAO work on EPA's advisory committees has focused on its Science Advisory Board--1 of 24 EPA federal advisory committees--which convenes panels to review many of the agency's scientific assessments and proposals. This testimony highlights scientific integrity and transparency issues GAO has reported on and relevant EPA reform efforts regarding (1) the IRIS assessment process and (2) federal advisory committee policies and procedures and appointment mechanisms. GAO has supplemented information from its prior reports with a preliminary review of the IRIS assessment process EPA issued on May 21, 2009, and the current appointment mechanisms for members of EPA's federal advisory committees.
section_title: What GAO Found
paragraphs: In March 2008, GAO reported that the database of chemicals assessed under the IRIS program was at serious risk of becoming obsolete because EPA had not been able to complete timely, transparent, and credible assessments or decrease its backlog of ongoing assessments. A revised IRIS assessment process EPA issued in April 2008 did not respond to GAO's recommendations; rather, it made changes likely to further exacerbate concerns GAO had identified. Largely as a result of EPA's lack of responsiveness, GAO added EPA's processes for assessing and controlling toxic chemicals as a high-risk area in its January 2009 biennial status report on governmentwide high-risk areas requiring increased attention by executive agencies and Congress. Taking positive action, EPA issued a new IRIS assessment process on May 21, 2009. In announcing these reforms, EPA echoed GAO's findings that the April 2008 assessment changes reduced the transparency, timeliness, and scientific integrity of the IRIS process. The IRIS reforms, if implemented effectively, will represent significant improvements. Among other things, they restore EPA's control of the process and increase its transparency. For example, under the prior process, interagency reviews were required and managed by the Office of Management and Budget (OMB) and EPA was not allowed to proceed with assessments at various stages until OMB notified EPA that it had sufficiently responded to comments from OMB and other agencies. In contrast, under the recently announced process, EPA is to manage the entire IRIS assessment process, including what are now called interagency consultations. In 2001, GAO reported on limitations in the policies and procedures developed by EPA's Science Advisory Board to ensure that its panels' peer reviewers are independent and that a balance of viewpoints is represented on each panel. These limitations could have reduced the effectiveness of the Board by contributing to its being perceived as biased and could have inadvertently exposed panelists to violations of federal conflict-of-interest laws. EPA revised the Board's policies and procedures, as GAO had recommended. In a broader 2004 report on federal advisory committees, GAO highlighted the Board's revised policies and procedures, and those of the National Academies, which can--if implemented effectively--provide an assurance that relevant conflicts of interest are identified and addressed and that the committees are balanced in terms of points of view. However, EPA currently appoints members to 16 of its federal advisory committees using an appointment mechanism reserved for cases in which members are to speak as representatives of identified entities and are not subject to conflict-of-interest reviews, rather than as individuals speaking on behalf of the government on the basis of their best judgment. While EPA may be appropriately seeking stakeholder advice from some of its advisory committees, a number of these committees focus on scientific and technical questions for which EPA is likely to be seeking advice on behalf of the government. As EPA works to enhance scientific integrity, a review of advisory committee appointments could help ensure that committee work is not jeopardized by allegations of conflicts of interest or bias.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the importance of scientific  integrity and transparency at the Environmental Protection Agency (EPA).  EPA’s ability to effectively carry out its mission to protect human health  and the environment is critically dependent on timely and credible  scientific and technical information and health risk assessments. Since  2001, we have issued a number of reports underscoring the importance of  integrity and transparency in processes that (1) develop the science used  to inform policy decisions and (2) are used to establish federal advisory  committees that, among other things, provide independent peer reviews of  EPA’s scientific determinations.
Notably, our work on EPA’s Integrated Risk Information System (IRIS)  program and its database—which contains the agency’s scientific position  on the potential human health effects of exposure to more than 540  chemicals—identified significant concerns about both the lack of  transparency in the process EPA uses to assess toxic chemicals and the  resulting effect on the credibility, or integrity, of these assessments. The  consequences of these transparency and credibility issues are  considerable because IRIS assessments are the cornerstone of  scientifically sound environmental decisions, policies, and regulations.  That is, the toxicity assessments in IRIS constitute the first two critical  steps of the risk assessment process. This process, in turn, provides the  foundation for risk management decisions, such as determining whether  EPA should establish controls for particular substances to protect the  public under such environmental laws as the Clean Air Act and the Safe  Drinking Water Act. (See fig. 1.)
EPA also seeks to enhance the quality and credibility of its highly  specialized scientific and technical products by using independent, expert  peer reviews. The 24 federal advisory committees EPA has established can  be important vehicles for such peer review. For example, the EPA Science  Advisory Board convenes panels to review many of the agency’s scientific  assessments and proposals. Because the work of fully competent peer  review panels can be undermined by allegations of conflict of interest and  bias, the best interests of federal advisory committees are served by  effective policies and procedures regarding potential conflicts of interest,  impartiality, and overall committee balance.
In this context, my testimony today discusses scientific integrity and  transparency issues and, where applicable, EPA reforms of the IRIS  assessment program and federal advisory committee policies and  procedures. My statement is based on findings from a number of reports  and testimonies we have issued since 2001 involving scientific integrity  and transparency issues at EPA. We have supplemented this testimony  with a preliminary review of EPA’s May 21, 2009, revisions to the IRIS  assessment process and of the current appointment mechanisms for EPA’s  24 federal advisory committees. Our preliminary analysis of IRIS reforms  focuses primarily on issues related to scientific integrity and transparency  and does not include IRIS productivity issues. We conducted our work  from May 26 to June 9, 2009, in accordance with generally accepted  government auditing standards. Those standards require that we plan and  perform our work to obtain sufficient, appropriate evidence to provide a  reasonable basis for our findings and conclusions based on our audit  objectives. We believe that the evidence obtained provides a reasonable  basis for our findings and conclusions based on our audit objectives.
subsections: section_title: EPA Reforms Have the Potential to Significantly Improve IRIS, but EPA Could Clarify Some Issues
paragraphs: In March 2008, we reported that the IRIS database—a critical component  of EPA’s capacity to support scientifically sound risk management  decisions, policies, and regulations—was at serious risk of becoming  obsolete because the agency had not been able to complete timely,  transparent, and credible chemical assessments or decrease its backlog of  ongoing assessments. In addition, assessment process changes EPA had  recently made, as well as other changes EPA was considering at the time  of our review, would have further reduced the credibility, transparency,  and timeliness of IRIS assessments. Among other things, we concluded the  following:    EPA’s efforts to finalize IRIS assessments have been impeded by a  combination of factors. These factors include (1) the Office of  Management and Budget’s (OMB) requiring two additional reviews of IRIS  assessments by OMB and other federal agencies with an interest in the  assessments, such as the Department of Defense, and (2) EPA  management decisions, such as delaying some assessments to await the  results of new research.
The two new OMB/interagency reviews of draft assessments involve other  federal agencies in EPA’s IRIS assessment process in a manner that limits  the credibility of IRIS assessments and hinders EPA’s ability to manage  them. For example, some of the agencies participating in these reviews  could face increased cleanup costs and other legal liabilities if EPA issued  an IRIS assessment for a chemical that resulted in a decision to regulate  the chemical to protect the public. Moreover, the input these agencies  provide to EPA is treated as “deliberative” and is not released to the  public. Regarding EPA’s ability to manage IRIS assessments, without  communicating its rationale for doing so, OMB required EPA to terminate  five assessments that for the first time addressed acute, rather than  chronic, exposure—even though EPA had initiated this type of assessment  to help it implement the Clean Air Act.
The changes to the IRIS assessment process that EPA was considering, but  had not yet issued at the time of our 2008 review, would have added to the  already unacceptable level of delays in completing IRIS assessments and  would have further limited the credibility of the assessments. For example,  the changes would have allowed potentially affected federal agencies to  have assessments suspended for up to 18 months to conduct additional  research. As we reported in 2008, even one delay can have a domino  effect, requiring the assessment process to essentially be repeated to  incorporate changing science.
In April 2008, EPA issued a revised IRIS assessment process. The process  was largely the same as the draft process we had evaluated during our  review and did not respond to the recommendations in our March 2008  report. Moreover, some key changes were likely to further exacerbate the  productivity and credibility concerns we initially identified. For example,  EPA’s revised process formally defined comments on IRIS assessments  from OMB and other federal agencies as “deliberative” and excluded them  from the public record. As we stated in our report, it is critical that input  from all parties—particularly agencies that may be affected by the  outcome of IRIS assessments—be publicly available. In addition, we  concluded that the estimated time frames under the revised process,  especially for chemicals of key concern, would likely perpetuate the cycle  of delays to which the majority of ongoing assessments have been subject.  Instead of streamlining the process, as we had recommended, EPA  institutionalized a process that from the outset was estimated to take 6 to  8 years for some widely used chemicals that are likely to cause cancer or  other serious health effects. This was particularly problematic because of  the substantial rework such cases often require to take into account  changing science and methodologies.
Largely as a result of EPA’s lack of responsiveness, we added transforming  EPA’s processes for assessing and controlling toxic chemicals as a high- risk area in our January 2009 biennial status report on governmentwide  high-risk areas requiring increased attention by executive agencies and  Congress. Taking positive action, on May 21, 2009, EPA issued a new IRIS  assessment process, effective immediately. In a memorandum announcing  the reforms to the IRIS assessment process, the EPA Administrator  echoed our prior findings that the April 2008 changes to the process  reduced the transparency, timeliness, and scientific integrity of the IRIS  process. She noted that the President’s recent emphasis on the importance  of transparency and scientific integrity in government decision making  compelled a rethinking of the IRIS process. If effectively implemented,  the new process would be largely responsive to the recommendations  outlined in our March 2008 report.
First, the new process and the memorandum announcing it indicate that  the IRIS assessment process will be entirely managed by EPA, including  the interagency consultations (formerly called OMB/interagency reviews).  Under EPA’s prior process, these two interagency reviews were required  and managed by OMB—and EPA was not allowed to proceed with  assessments at various stages until OMB notified EPA that it had  sufficiently responded to comments from OMB and other agencies. The  independence restored to EPA under the new process is critical in  ensuring that EPA has the ability to develop transparent, credible IRIS  chemical assessments that the agency and other IRIS users, such as state  and local environmental agencies, need to develop adequate protections  for human health and the environment.
Second, the new process addresses a key transparency concern  highlighted in our 2008 report and testimonies.  As we recommended, it  expressly requires that all written comments on draft IRIS assessments  provided during the interagency consultation process by other federal  agencies and White House offices be part of the public record.
Third, the new process streamlines the previous one by consolidating and  eliminating some steps. Importantly, EPA eliminated the step under which  other federal agencies could have IRIS assessments suspended in order to  conduct additional research, thus returning to EPA’s practice in the 1990s  of developing assessments on the basis of the best available science. As  we highlighted in our report, as a general rule, requiring that IRIS  assessments be based on the best science available at the time of the  assessment is a standard that best supports the goal of completing  assessments within reasonable time periods and minimizing the need to  conduct significant levels of rework.
Fourth, as outlined in the EPA Administrator’s memorandum announcing  the new IRIS process, the President’s fiscal year 2010 budget request  includes an additional $5 million and 10 full-time-equivalent staff positions  for the IRIS program, which is responsive to our recommendation to  assess the level of resources that should be dedicated in order to meet  user needs and maintain a viable IRIS database.
We are encouraged by the efforts EPA has made to adopt most of our  recommendations, including those addressing transparency practices and  streamlining the lengthy IRIS assessment process. The changes outlined  above reflect a significant redirection of the IRIS process that, if  implemented effectively, can help EPA restore the integrity and  productivity of this important program. Nevertheless, on the basis of our  preliminary review of the new IRIS assessment process, we have some  initial questions that EPA may wish to consider as it implements its new  process. For example, regarding integrity and transparency, it is not clear    whether any significant agreements reached among the federal agencies  during interagency consultation meetings will be documented in the public  record, since the new policy specifies only that written comments  provided by other federal agencies will become part of the public record;  and     why comments from other federal agencies cannot be solicited at the same  time the initial draft is sent to independent peer reviewers and public  comments are solicited. This change would enhance transparency and  would further reduce overall assessment time frames. Specifically, the  public and peer reviewers could have greater assurance that the draft had  not been inappropriately biased by policy considerations of other  agencies, including those that may be affected by the outcome, such as the  Department of Defense and the Department of Energy.
In addition, the new assessment process states that “White House offices” will  be involved in the interagency consultation process but does not indicate  which offices.  Given that (1) EPA will be performing the coordinating role  that OMB exercised under the prior process and (2) the purpose of these  consultations is to obtain scientific feedback, it is unclear whether OMB will  continue to be involved in the interagency consultation process.
section_title: EPA Has Improved the Policies and Procedures of Its Science Advisory Board, but Their Wider Use by Other EPA Scientific Advisory Committees Could Enhance EPA’s Scientific Integrity
paragraphs: Independent, expert peer review of EPA’s scientific and regulatory  products, such as risk assessments and proposed rules, is integral to the  agency’s ability to effectively protect public health and the environment.  Specifically, using peer review, EPA seeks to enhance the quality and  credibility of the agency’s highly specialized products. One of the several  ways EPA obtains expert peer review is from advice and  recommendations it requests of its 24 federal advisory committees  comprising independent experts. For example, since its inception in 1978,  one of EPA’s largest and most prominent federal advisory committees— the EPA Science Advisory Board—has convened hundreds of peer review  panels to assess the scientific and technical rationales underlying a wide  range of current or proposed EPA regulations and policies. The IRIS  program uses Science Advisory Board panels to peer review some of its  particularly complex chemical assessments, and the Board is currently  expanding a panel that will review existing IRIS assessment values  established more than 10 years ago. Federal advisory committees such as  the Science Advisory Board are subject to the requirements of the Federal  Advisory Committee Act (FACA), which include broad requirements for  balance, independence, and transparency.
To be effective, peer review panels must be—and also be perceived to  be—free of any significant conflict of interest and uncompromised by bias.  Peer review panels should also be properly balanced, allowing for a  spectrum of views and appropriate expertise.
These standards, reflected in the act, are important because the work of  fully competent peer review panels can be undermined by allegations of  conflict of interest and bias.
In 2001, we reported on limitations in the policies and procedures  developed by EPA’s Science Advisory Board to ensure that its panels’ peer  reviewers are independent and that a balance of viewpoints is represented  on each panel. These limitations could reduce the effectiveness of the  Board overall by contributing to its being perceived as biased and could  inadvertently expose some panelists to violations of federal conflict-of- interest laws. Demonstrating a strong commitment to the integrity of its  peer reviews, EPA took a number of actions to implement our report’s  recommendations, including    establishing a standard process for Science Advisory Board panel  formation that includes a requirement to document decisions about  conflicts of interest and balance of viewpoints and expertise in forming  each panel, as well as prospective panelists’ responses to several  standardized questions aimed at assessing impartiality;    developing a new confidential financial disclosure form designed to  capture needed information to evaluate potential conflicts of interest;    allowing the public to review a “short list” of candidates selected for a  specific Science Advisory Board panel and to comment on the  appropriateness of including any of these candidates on the panel; and    developing CD-based conflict-of-interest training for Science Advisory  Board panelists.
In 2004, we reported on the policies and procedures at nine federal  departments and agencies, including EPA, that extensively use federal  advisory committees. We also identified practices that promote  independence and balance used by the National Academies and the EPA  Science Advisory Board. Regarding the latter issue, we concluded that  the National Academies and the EPA Science Advisory Board have  developed clear processes that, if effectively implemented, can provide  these organizations with an assurance that relevant conflicts of interest  are identified and addressed—and that committees are appropriately  balanced in terms of points of view. Specifically, we found that the  processes used by the National Academies and EPA’s Science Advisory  Board clearly and consistently  identify the information they deem necessary to assess candidates for  independence and to balance committees,    explain to the candidates why the required information is important to  protect the integrity of the committee’s work,  request public comment on proposed committee membership, and  require evaluation of the overall balance of committees before committees  are finalized.
Regarding the federal advisory committee policies and procedures at nine  departments and agencies, in 2004 we found that the Departments of  Agriculture, Energy, and the Interior had a long-standing practice of  appointing most or all members of their federal advisory committees as  “representatives”—expected to reflect the views of the entity or group  they are representing and not subject to conflict-of-interest reviews—even  when the departments called upon the members to provide advice on  behalf of the government on the basis of their best judgment and thus  should have appointed them as special government employees. That is,  members of federal advisory committees that are providing advice on  behalf of the government should be appointed as “special government  employees”—short-term or intermittent employees subject, with some  important modifications, to the conflict-of-interest requirements  applicable to other federal employees. We also reported that  representative appointments are generally not appropriate for scientific  and technical advisory committees, which typically provide advice on  behalf of the government. We made recommendations to the two agencies  responsible for overseeing aspects of federal advisory committees to,  among other things, provide additional guidance to federal agencies on the  appropriate use of representative appointments. In response, these  agencies issued such guidance in 2004 and 2005. (See appendix I for  additional information on our 2004 federal advisory committee  recommendations.)
The two scientific EPA federal advisory committees we assessed in our  2004 report appropriately appointed their members as special government  employees. We note that 16 of the 24 EPA federal advisory committees  currently use representative appointments, according to the government’s  database of federal advisory committee information. While EPA may be  appropriately seeking stakeholder advice from some of these advisory  committees, a number of its committees focus on scientific and technical  questions for which EPA is likely to be seeking advice on behalf of the  government on the basis of committee members’ best judgment, rather  than stakeholder advice. EPA’s scientific and technical committees using  representative appointments include the National Advisory Committee for  Acute Exposure Guideline Levels for Hazardous Substances, the Coastal  Elevations and Sea Level Rise Advisory Committee, the Environmental  Laboratory Advisory Board, and the Children’s Health Protection Advisory  Committee. In reviewing information about EPA’s committees, we found  that descriptions of the objectives and scope of committee activities for  EPA committees using representative appointments are similar to such  descriptions for EPA committees using special government employees,  such as the Science Advisory Board; the Federal Insecticide, Fungicide,  and Rodenticide Science Advisory Panel; the National Drinking Water  Advisory Council; and the Human Studies Review Board.
As EPA moves forward with actions to enhance its scientific integrity, it  will be appropriate for the agency to review its federal advisory committee  appointments, especially those for which it appoints members as  representatives, to help ensure that committee work is not jeopardized by  allegations of conflict of interest or bias. As discussed earlier, committee  members appointed as representatives are not evaluated for potential  conflicts of interest. If some EPA committee members are inappropriately  appointed as representatives, EPA cannot be assured that any real or  perceived conflicts of interest of their committee members who provided  advice on behalf of the government were identified and appropriately  mitigated. Further, allegations that the members had conflicts of interest  could call into question the independence of the committee and jeopardize  the credibility of the committee’s work.
Advisory committee charters generally expire at the end of 2 years unless  renewed by the agency or Congress. The EPA committees with  representative members discussed earlier have charters expiring in 2009  and 2010. As it reviews its policies and procedures to ensure scientific  integrity, EPA could either comprehensively review the appointments of  its 16 committees with representative members or, alternatively, review  them as the charters are renewed. We note that EPA has in-house  expertise in managing federal advisory committees composed of special  government employees—for example, the staff who administer and  coordinate Science Advisory Board committees—and thus should be well  positioned to address this issue.
In conclusion, EPA’s most recent changes to the IRIS assessment process,  if effectively implemented, would represent a significant improvement  over the process put in place in 2008.  Among other things, the reforms  appropriately restore EPA’s control of the IRIS process and increase the  transparency of the process. In addition, EPA was responsive to our 2001  recommendations for improving the independence and balance of  committees convened by EPA’s Science Advisory Board by developing  policies and procedures that represent best practices. As a result, if these  policies and procedures are implemented effectively, EPA can have an  assurance that its Science Advisory Board panels are independent and  balanced as a whole. However, a number of EPA’s other federal advisory  committees do not appear to have benefited from the steps the Science  Advisory Board has taken to enhance the integrity and transparency of its  committees. As EPA takes additional steps to comply with the President’s  March 9, 2009, memorandum on scientific integrity, we believe that EPA’s  scientific processes could be further enhanced by considering our  questions about some aspects of the IRIS assessment process and  reviewing its federal advisory committee appointments.
Madam Chairman, this concludes my prepared statement. I would be  happy to respond to any questions that you or other Members of the  Committee may have at this time.
section_title: GAO Contacts and Staff Acknowledgments
paragraphs: For further information about this testimony, please contact John B.  Stephenson at (202) 512-3841 or stephensonj@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found on  the last page of this statement. Contributors to this testimony include  Christine Fishkin (Assistant Director), Laura Gatz, Richard P. Johnson,  Summer Lingard, Nancy Crothers, Antoinette Capaccio, and Carol Kolarik.
section_title: Appendix I: Information on GAO’s 2004 Federal Advisory Committee Recommendations
paragraphs: Following are highlights of the recommendations in our 2004 report,  Federal Advisory Committees: Additional Guidance Could Help Agencies  Better Ensure Independence and Balance, to the General Services  Administration (GSA) and the Office of Government Ethics (OGE). These  agencies oversee aspects of federal advisory committees. Specifically, GSA  develops guidance on establishing and managing Federal Advisory  Committee Act (FACA) committees, and OGE develops regulations and  guidance for statutory conflict-of-interest provisions that apply to special  government employees.
Our 2004 report contained recommendations to GSA and OGE to, among  other things, provide additional guidance to federal agencies on the  appropriate use of representative appointments. Specifically, we  recommended that guidance from OGE to agencies be improved to better  ensure that members appointed to committees as representatives were, in  fact, representing a recognizable group or entity. OGE agreed that some  agencies may have been inappropriately identifying certain advisory  committee members as representatives instead of special government  employees and issued guidance documents in July 2004 and August 2005  that clarified the distinction between special government employees and  representative members. In particular, as we recommended, OGE’s  clarifications included that (1) members should not be appointed as  representatives purely on the basis of their expertise and (2) appointments  as representatives are limited to circumstances in which the members are  speaking as stakeholders for the entities for groups they represent.
We also recommended that OGE and GSA modify their FACA training  materials to incorporate the changes in guidance regarding the  appointment process, which they have done. In addition, we  recommended that GSA expand its FACA database to identify each  committee member’s appointment category and, for representative  members, the entity or group represented. GSA quickly implemented this  recommendation and now has data on appointments beginning in 2005.  Finally, we recommended that OGE and GSA direct agencies to review  their appointments of representative and special government employee  committee members to make sure they are appropriate. OGE’s 2004 and  2005 guidance documents addressed this issue by, among other things,  recommending that agency ethics officials periodically review  appointment designations to ensure they are proper.
section_title: Related GAO Products
paragraphs: High-Risk Series, An Update. GAO-09-271. Washington, D.C.: January.  2009.
EPA Science: New Assessment Process Further Limits the Credibility  and Timeliness of EPA’s Assessments of Toxic Chemicals. GAO-08-1168T.  Washington, D.C.: September 18, 2008.
Environmental Health: EPA Efforts to Address Children’s Health Issues  Need Greater Focus, Direction, and Top-Level Commitment.   GAO-08-1155T. Washington, D.C.: September 16, 2008.
Chemical Assessments: EPA’s New Assessment Process Will Further  Limit the Productivity and Credibility of Its Integrated Risk  Information System. GAO-08-810T.  Washington, D.C.: May 21, 2008.
Toxic Chemicals: EPA’s New Assessment Process Will Increase  Challenges EPA Faces in Evaluating and Regulating Chemicals.  GAO-08-743T. Washington, D.C.: April 29, 2008.
Federal Advisory Committee Act: Issues Related to the Independence and  Balance of Advisory Committees. GAO-08-611T. Washington, D.C.:   April 2, 2008.
Chemical Assessments: Low Productivity and New Interagency Review  Process Limit the Usefulness and Credibility of EPA’s Integrated Risk  Information System. GAO-08-440. Washington, D.C.: March 7, 2008.
Federal Advisory Committees: Additional Guidance Could Help Agencies  Better Ensure Independence and Balance. GAO-04-328. (Washington,  D.C.: April 16, 2004.
EPA’s Science Advisory Board Panels: Improved Policies and Procedures  Needed to Ensure Independence and Balance. GAO-01-536. Washington,  D.C.: June 12, 2001.
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