On August 31, the Department of the Interior (DOI) released its proposed scientific integrity policy and is seeking comments until September 20, reports the Wildlife Management Institute. The policy was spurred by a March 2009 memo from President Obama directing agencies to develop such policies by working closely with the Director of the Office of Science and Technology Policy (OSTP). Although providing a code of conduct for employees or contractors involved in scientific research and detailed disciplinary actions, the policy is inadequate critics say, because it would not affect political appointees and senior leadership within the agencies.

Several high profile situations in the last decade undermined public trust and elevated the need for a formal scientific integrity policy. In 2002, Fish and Wildlife Service biologists submitted unauthorized Canada lynx hair samples in a research study, compromising the overall viability of the study. In addition, a former Deputy Assistant Secretary was found to have edited and changed scientific research that affected critical habitat and endangered species designations. And a National Park Service senior science advisor for Point Reyes National Seashore was found to have misrepresented research regarding sedimentation and to have misinformed individuals in a public forum regarding sea life data.

Given these and other cases, DOI has touted the need to ensure departmental scientific integrity. Upon his confirmation in early 2009, Secretary of the Interior Salazar pledged a commitment to high ethical standards and respect for scientific integrity. However, a report released in April 2010 by the DOI Inspector General (IG) disclosed that the Department does not have a comprehensive scientific integrity policy and only one agency, the U.S. Geological Survey, has such a policy in place.

The IG report recommendations to the Secretary were to:

1. Develop and implement a DOI-wide comprehensive scientific integrity policy that addresses required elements of the OSTP scientific misconduct policy, to include provisions for both internal and external scientific research, applicable to all agents, appointees, employees and contractors involved in researching and publishing scientific results of any kind, include a misconduct allegation reporting requirement, and a range of disciplinary actions.

2. Designate a responsible official to guide the development and implementation of a DOI-wide scientific integrity policy and to oversee the bureaus' implementation and application of the policy.

A letter to Secretary Salazar by professional science organizations, including The Wildlife Society and the Society for Conservation Biology, supported the IG report: "Without a transparent and ethical process for dealing with scientific research and scientific conduct, the science that is performed at DOI may continue to be called into question. This will not only harm the reputation of DOI, but will threaten the conservation of the nation's treasured natural resources. Therefore, to ensure that the science is being used properly to implement natural resource decisions, science that contradicts these decisions should not be suppressed, scientific misconduct should be punished, and scientists who report suppression or other scientific misconduct should be afforded whistleblower protections."

The new draft policy commits DOI to preserving the integrity of scientific activities conducted on its behalf and emphasizes its intention to investigate allegations of misconduct. The policy applies to all employees and contractors who engage in scientific activities. It also applies to volunteers who assist employee and contractor efforts and defines volunteers as those who specifically conduct or supervise scientific activities as well as those that supervise or personally compile or translate the research for DOI decision makers. There is a 12-point code of conduct to which personnel will be expected to adhere. The policy clearly states that appropriate disciplinary action, including potential termination, will be taken against personnel found in non-compliance.

"Scientific activities provide data to inform many of the Department's decision-makers regarding the stewardship of our Nation's land, energy, mineral, water, air, biological, and cultural resources," the policy reads. "Employees subject to the Code must avoid conflicts of interest that occur when personal interest or gain interferes with or could be construed to interfere with the objectivity of their actions or judgments. They are obligated to be thorough in documenting their work to ensure that the details of their methods are described adequately enough to allow other scientists to critically evaluate or reproduce their results. They will use the best available and practicable practices, protocols, methodologies and technologies available to them when conducting scientific activities as well as in the review, use and dissemination of scientific information."

The draft policy has been criticized because it only affects those directly involved in the science and does not pertain to the decision makers who may attempt to reinterpret research findings.

"I certainly take seriously the comment that what the Department of Interior released is far from a comprehensive approach to the challenges," Director of the White House Office of Science and Technology Policy, John Holdren, said. "As we come to issuing the new recommendation, I will be certain to work very closely with the Department of Interior to make sure that their guidelines are compatible with our more comprehensive approach." (jas)