The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted formal comments to the Environmental Protection Agency (EPA) regarding the agency's draft Scientific Integrity Policy. While COGR strongly supports the policy's overall goal of enhancing scientific integrity and promoting transparent, objective research, the organization raises concerns about the policy’s ambiguous language related to its applicability to EPA research award recipients (“Grantees”). Specifically, COGR states that the policy lacks clarity on when and how its provisions apply to grantees, which could hinder compliance and implementation at member institutions.
COGR recommends that the EPA revise the policy to explicitly state that its requirements apply solely to research activities financially supported by the EPA, so as to avoid conflicts with other funding agencies’ policies. Additionally, the organization urges EPA to clarify which specific provisions pertain to grantees, as opposed to other covered entities such as EPA employees or contractors. Examples cited include the requirements for scientific integrity training and independent validation of scientific models, where the roles and responsibilities of grantees are not clearly delineated. COGR concludes by emphasizing the importance of clear, unambiguous policy language to support effective collaboration between grantees and the EPA in advancing scientific integrity.
