Memorandum - Implementation of Departmental Scientific Integrity Policy
To: All Heads of Operating Administrations and Secretarial Officers
This memorandum implements within the U.S. Department of Transportation (DOT) the Administration’s policy on scientific integrity. It will serve as the framework for any modal scientific integrity policies and for a DOT Scientific Integrity Policy Implementation Manual that will provide further direction on the issue.
On March 9, 2009, President Obama issued a memorandum articulating six principles central to the preservation and promotion of scientific integrity (see Attachment 1). On December 17, 2010, the Director of the Office of Science and Technology Policy (OSTP) issued a memorandum providing further guidance to executive departments and agencies to implement the Administration’s policies on scientific integrity (see Attachment 2). Consistent with the OSTP memorandum, this memorandum establishes a Department-wide policy to guide and ensure the integrity of science and scientific products. It also should guide the formation of any scientific integrity policies developed within the operating administrations.
The context for the scientific integrity policy is scientific research. The overriding intent of this policy is that political appointees must not exert undue influence over scientists in the conduct of scientific research. Recognizing that the nature of the scientific inquiry includes formulating and exploring questions, it is to be expected that scientists may have different perspectives and develop multiple approaches in their research. The existence of disputes in research is not inconsistent with scientific integrity or with a policy that political appointees must not exercise undue influence over scientific inquiry.
This policy is not intended to stifle debate, but rather to allow scientific inquiry to flourish. Political appointees may consider any and all scientific research and policy aims that are permitted by law.
The Department is dedicated to preserving the integrity of the research it conducts and funds. It will not tolerate misconduct in the performance of these activities nor in the application of these activities to decision-making. This policy clearly defines the roles and responsibilities of DOT career staff and political appointees in upholding the principles of scientific integrity and conduct.
Political appointees at DOT should never suppress or alter research findings or conclusions. Political appointees are not to censure or coerce DOT employees to alter scientific findings. This policy also protects DOT employees that uncover and report such misconduct. This policy encompasses all sciences including all hard, natural and life, and social sciences, and all findings including results derived from data (actual or simulated).
This policy consists of the following nine elements:
- When DOT uses scientific or technological information in decision-making, that information will be the result of the most rigorous scientific processes that DOT can achieve within the available time and resources. The Department will document and make available to the public the scientific findings that are considered in its decision-making process to the extent allowable by law. Where appropriate, this should include data and models underlying regulatory proposals and policy decisions.
- The Department will communicate scientific and technological findings by including a clear explanation of underlying assumptions, including accurate contextualization of uncertainties, and describing the probabilities associated with both optimistic and pessimistic projections, including best-case and worst-case scenarios where appropriate.
- Data and research used to support DOT policy decisions will undergo independent peer review by qualified experts when required and consistent with law.
- The Department will facilitate the free flow of scientific and technological information, consistent with privacy and classification standards and applicable law. To this end, DOT will expand and promote access to scientific and technological information by making it available online in open formats, consistent with the Administration’s Open Government Initiative. Where appropriate, this will include data and models underlying regulatory proposals and policy decisions.
- Political appointees will not suppress or alter scientific findings. They will not coerce employees to suppress or alter findings.
- The Department will have rigorous whistleblower protections to ensure scientific integrity in decision-making.
- The Department will not discipline an employee for refusing to alter findings at the request of a political appointee.
- The basis for the selection of candidates for science and technological positions will be the candidate’s knowledge, credentials and experience. The Department will not hire individuals for these positions who do not have adequate credentials.
- The Department will identify, address, track, and resolve instances in which scientific integrity has been compromised.
In response to media requests concerning scientific dimensions of work, DOT will offer articulate and knowledgeable subject matter experts who can describe the work in an objective manner. With coordination from their immediate supervisor and the public affairs office, DOT scientists may speak to the media and the public about technological matters based on their official duties.
Supervisors and public affairs officers will not ask or direct federal scientists to alter or suppress findings. The Department will have mechanisms in place, as described in the forthcoming DOT Scientific Integrity Policy Implementation Manual, to resolve disputes that arise from decisions not to proceed with proposed interviews or other public information-related activities.
The Department promotes the professional development of its scientific staff that is consistent with Federal ethics rules, job responsibilities and existing DOT policy regarding political appointees. Scientific staff is encouraged to present research findings at professional meetings and to publish findings in professional and scholarly journals, consistent with applicable law. To the extent permitted by the federal ethics laws and regulations, DOT scientists can participate in professional societies and serve on committees, boards, and other working groups of these societies. Also, to the extent permitted by Federal ethics laws and regulations, scientists and engineers may receive honors and awards for their research and discoveries with the goal of minimizing, to the extent practicable, disparities in the potential for private-sector and public-sector scientists and engineers to accrue the professional benefits of such honors or awards.
The DOT will be transparent in its recruitment of members to Federal Advisory Committee Act committees (FACA committees) and its dissemination of professional biographic information of members. Except where prohibited by law, DOT will make any Conflict of Interest waivers granted to committee members publicly available. Factors to be considered in the selection of members to serve on a scientific or technical FACA committee will be expertise, knowledge, and contribution to the relevant subject area. Additional factors that may be considered are: the availability of the member to serve, diversity among members of the FACA committee, and the ability to work effectively on advisory committees. Committee membership will be balanced in terms of points of view represented with respect to the functions to be performed by the FACA committee. Unless prohibited by statute or regulation, all reports, recommendations, and other products produced by a scientific or technical FACA committee will be treated solely as products of such committee rather than of DOT, and thus are not subject to DOT revision.
This memorandum implements all aspects of the attached White House memoranda. The Department will develop an accompanying Scientific Integrity Policy Implementation Manual to serve as further guidance on the issue.
I have designated Dr. Kevin Womack, the Research and Innovative Technology Administration’s Associate Administrator for Research, Development and Technology, as the Department’s Scientific Integrity Officer (DSIO) to provide DOT leadership, coordination and guidance. The DSIO will also be a point of contact with the corresponding Scientific Integrity Officers in the Operating Administrations.
The memorandum is effective immediately insofar as its principles shall be implemented at the soonest possible date. The entirety of the DOT Scientific Integrity Policy shall be effective upon publication of the forthcoming Scientific Integrity Policy Implementation Manual.
Authority (Statutes, Regulations, and Policy)
5 U.S.C. 301 allows the head of an Executive Department to prescribe regulations for the conduct of its employees.
The Information Quality Act, Consolidated Appropriations Act of 2001. Title V, Section 515 (Pub. L. 106-554).
Federal Acquisition Manual, 48 C.F.R. 1252.235-70, Research Misconduct.
Federal Policy on Research Misconduct, 65 F.R. 76260-76264, December 6, 2000.
DOT Order 1100.75. Implementation Guidance for Executive Office of the President, Office of Science and Technology Policy “Federal Policy on Research Misconduct.” U.S. DOT, Research and Technology Coordinating Council, February 2002.
Standards of Ethical Conduct for Employees of the Executive Branch, 5 C.F.R. 2635.
- President's Memorandum on Scientific Integrity (March 9, 2009)
- Memorandum for the Heads of Executive Departments and Agencies: Scientific Integrity, OSTP, December 17, 2010.