The Council on Governmental Relations (COGR) submitted a detailed response to the National Science Foundation’s (NSF) Request for Information concerning the incorporation of ethical, social, safety, and security considerations into the agency’s merit review process, as mandated by the CHIPS and Science Act, Section 10343. COGR emphasizes the importance of clear and consistent definitions of risk categories—ethical, social, safety, and security—highlighting the need for alignment with existing federal definitions and frameworks. They recommend that NSF inventory current laws, regulations, and risk assessment procedures before developing new policies, and propose that the agency build upon established ethical frameworks, such as the Belmont Report, rather than creating redundant or burdensome review processes.
Further, COGR suggests that rather than requiring uniform, detailed risk assessments for all research proposals, NSF should adopt a risk-based approach, focusing additional scrutiny on higher-risk projects and allowing streamlined processes for low-risk activities. They highlight existing practices, like the “Broader Impacts” requirement, and caution against overburdening researchers with speculative risk assessments, particularly where they lack access to relevant information, such as in cases involving national security. COGR also underscores the importance of thoughtfully updating training for both applicants and reviewers to ensure effective risk evaluation without stifling innovation or deterring talent from federally funded research. Overall, the response advocates for leveraging existing governance structures, fostering collaboration with stakeholders, and ensuring that new requirements do not inadvertently drive research into less-regulated private sectors or discourage participation in the STEM fields.
