Excerpt of Administrator’s Remarks to the Union of Concerned Scientists about Scientific Integrity at NOAA

As delivered on Feb. 8 by Jane Lubchenco, Ph.D., under secretary of commerce for oceans and atmosphere and NOAA administrator

February 9, 2011

Many thanks for the invitation to join you tonight. My focus will be on the progress we’ve made in strengthening scientific integrity within NOAA, both the policies we’re formulating and the practices we are implementing.

But first – I thank UCS for your role in championing scientific integrity. The spotlight you’ve shone on the topic and the specific suggestions you have offered have been critical to the overall goal of strengthening science and protecting its integrity, including the generation, communication and use of science by federal agencies.

The President is deeply committed to scientific integrity. I know this because the President-Elect and I discussed scientific integrity when we met in Chicago in December of 2008. I know this because President Obama made the appointment of strong scientists in key positions a hallmark of his administration, and he did so very early in the appointment process. I had the privilege of being part of the Science Team that the President nominated in December, 2008, well before most other appointments.

And, true to his word, the President issued his Memorandum on Scientific Integrity on March 9, 2009, just a few weeks after his inauguration. That Memorandum laid out key principles to guide agency action from the early days of this administration.

Hence, as you have noted, this administration took early, strong and decisive action on scientific integrity.

The fact that the follow-up guidance from OSTP, Dr. Holdren’s December 17, 2010 memorandum to agencies took longer than expected reflects the complexity of the issues. In the interim, however, the President’s Memorandum guided our actions. Moreover, during that time, a number of agencies began reviews of their policies.

One of my first actions after I was confirmed March 19, 2009 was to appoint a scientific integrity team at NOAA. Their charge was to review the state of science and scientific integrity at NOAA, to actively assist OSTP in developing recommendations that would strengthen the integrity of science in government, and to draft a scientific integrity policy for NOAA. This latter task has been under construction for over a year, and was timed to incorporate further guidance from OSTP.

I am proud that many of the issues raised by our team were incorporated into the OSTP policy.

Once the OSTP policy was released, our team continued work on our draft policy to ensure it is consistent with OSTP’s guidance.

Our process has been deliberate and inclusive. I believe it is vitally important that the policy have strong input from the multiple parts of NOAA that must be engaged: scientists, communicators, managers, and policy experts. We are now poised for the next step in this process – the engagement of our entire workforce.

At the same time, we are engaging regularly and often with the Department of Commerce and with other scientific Bureaus in the Department to ensure consistency of approach and mutual support for implementation of policies.

I am pleased to inform you that earlier today we shared NOAA’s DRAFT scientific integrity policy with all 12,800 employees of NOAA for their review and comment. Once we have incorporated their input, we will release a draft for public comment, make revisions as needed, ensure it is compatible with departmental and administration-wide policies, and issue it as a final policy. We anticipate these various steps will likely take a number of months to complete.

Transparency is one of the key principles of this draft policy, which is why the first draft was developed by an ad hoc committee of NOAA scientists and science managers. And why our first step is to engage all our employees in its development, since they are the ones who will be most affected. After NOAA’s employees have a chance to provide their feedback, we will reach out to our partners, to the public, and to you, as part of a public comment opportunity – again, in the spirit of being open and transparent.

Do I wish we had been able to move this entire process along much faster? Absolutely! Nonetheless, I am pleased that the good work is finally coming to fruition. And the end result will be stronger for having engaged all of the relevant parties.

The long wait says absolutely nothing about my commitment to the honest and open conduct of science at NOAA. Let me be absolutely clear on this point. I am firmly committed to instituting a strong and prominent scientific integrity policy at NOAA. As a federal science agency, we have a responsibility – no, we have an obligation to conduct science in a way that makes us exemplary contributors to scientific knowledge, the scientific community, and the common good.

Scientific integrity is at the core of conducting ethical science.

The character of the knowledge we build, and the understanding of the world we derive from that knowledge, depend on the integrity of the process used to generate that knowledge, the integrity of the people involved, and on how that knowledge is shared.

By being open and honest about our science, we build understanding and trust. Freely and honestly sharing science means we invite open discussion of the process, the evidence, the interpretations and the applications to policy and practice. And it means the knowledge is revised through time.

Free and open inquiry is the backbone of science. Free and open inquiry is the backbone of democracy. When we stand up for scientific integrity, we stand up for democracy.

This is what I think of as the “rightful place” of scientific integrity. This is why I am so firmly committed to seeing a meaningful and well-executed scientific integrity policy in this Administration and in NOAA.

I’ve said it before and I’ll say it again: a key role of science is to inform policy. I use the word ‘inform’ judiciously: science should not dictate policy, it should inform it. Policies will and should be based on a number of factors, including values, politics, economics, etc., but science should be well represented at the table. And that science needs to be trustworthy.

Moreover, science is not, and should not be made to be, partisan. Policies that are informed by science will be better and most helpful to society.

From my earliest days at NOAA, I have championed scientific integrity. And the NOAA team has responded enthusiastically. Four days after being sworn in, I said to NOAA employees at my first Town Hall, “I pledge to bring diligence, transparency, fairness, integrity and accountability to the job in a collaborative fashion. I expect the same from you." And we have done just that, as a team.

In addition to the vigorous activities on formulating our policy on scientific integrity, the NOAA team has responded actively to my request for ways to strengthen science and scientific careers at NOAA.

In a single year, we have more than doubled the number of senior science positions at NOAA – from 10 to 25.

In April 2010 as part of our process to revise NOAA’s strategic plan, 70 scientists and science managers convened at the first-ever, NOAA-wide workshop on strengthening NOAA science. In addition to offering a plethora of useful ideas, they shouted out for a clarification of NOAA’s scientific integrity guidance.

Shortly thereafter, the Deepwater Horizon disaster began to unfold and took priority over many activities underway at NOAA.

So what is in NOAA’s new policy? In short, it takes significant steps toward fleshing out the administration-wide guidance. It does not provide all of the specificity that we will eventually want, but it represents excellent progress.

The NOAA draft policy lays out guidance for scientific conduct at NOAA. It includes a “Code of Scientific Conduct.” And it focuses on the conditions for creating a climate where science is encouraged, nurtured, respected, rewarded and protected. The policy is about creating the conditions for enabling first-rate science and guarding against attempts to undermine or discredit it. And the policy is about the key role of science in informing policy.

The NOAA policy is designed to ensure a culture of transparency, integrity, and ethical behavior in NOAA.

The NOAA policy says is that our core values are transparency, traceability, and integrity.

NOAA scientists are encouraged to publish their data and findings. Doing so advances science, their careers, and contributes to NOAA’s reputation for reliable science. All publication vehicles -- online open formats, peer-reviewed, professional, and scholarly journals –are encouraged.

The draft NOAA policy explicitly states that NOAA science managers and supervisors, political and career, must never suppress, alter or otherwise impede the timely release of scientific or technological findings or conclusions.

Complementing the above foci, the policy makes clear that NOAA scientists are encouraged to be leaders in the scientific community. We want them to fully engaged with their peers and participate actively in professional scientific meetings and societies. When NOAA employees are elected or appointed to positions on professional scientific organizations (including becoming officers and sitting on governing boards), NOAA’s reputation as a science agency benefits. But unlike academia, NOAA and other federal agencies have to be mindful of potential conflict of interest issues at the institutional level as well at the individual level.

Whistleblowing protection is also part of the draft NOAA policy.

The policy will apply to everyone -- career federal employees, political appointees, and contractors -- and it is relevant whether one engages in, supervises, analyzes, or communicates scientific data and findings.

In order to make sure that all NOAA personnel have maximum opportunity to understand and benefit from the policy, we will develop and implement a training program as soon as possible after the policy is completed.

We eagerly await the review and input by our employees, and subsequent comments by you and other interested parties. We believe that we are on the right track and anticipate making systemic changes to ensure durability of the new principles and guidelines.


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