IFT Comments to OSTP on Scientific Integrity

May 1, 2009

Commentary on Scientific Integrity
Provided to the Office of Science and Technology Policy
by the Institute of Food Technologists

Via email: scientificintegrity@ostp.gov

Founded in 1939, the Institute of Food Technologists (IFT) is a not‐for‐profit international scientific and educational society of food scientists and technologists working in government, academia, and the food industry. IFT is a diverse organization comprised of more than 20,000 individual members working in every aspect of the farm‐to‐table food system. IFT exists to advance the science of food, and we share the long‐range vision of a safe and abundant food supply that contributes to healthier people around the world.

As President Barack Obama described in his remarks to the National Academy of Sciences April 27, 2009, long term solutions to current challenges in the financial, healthcare, and energy sectors and in the areas of economic and scientific competitiveness and national security necessitate renewed commitments to basic scientific research and technological innovation in the public as well as private sectors. IFT agrees with President Obama about the need for increased investment in science. Increased investment in the science of food is particularly important. Additionally, it is imperative that policies and management practices relating to sustainable use of water, energy and other resources for food production at the local level and on a global scale be addressed to enhance the safety and sufficiency of our global food supply. IFT is thus very pleased to have this opportunity to provide comments to the White House Office of Science and Technology Policy (OSTP) in response to the President’s request that OSTP consider recommendations for ensuring that federal policies are based on the best and most unbiased scientific information and for ensuring scientific integrity in the executive branch of government.

IFT also agrees with President Obama that the integrity of scientific outcomes should never be compromised by political influence from the executive branch. The science base that is taken into account in policy development should have no hint of political interference. A fundamental principle of scientific integrity is that it is inappropriate to apply political criteria to the selection or suppression of scientific information. Likewise, in the interest of developing science‐based policy it is inappropriate to apply political criteria to the choice of individuals for positions as scientists or technologists in executive‐branch agencies.

IFT offers below specific comments to OSTP. Our comments are organized by the specific principles for scientific integrity as presented in the President’s memorandum to the heads of executive departments and agencies.

(a) Selection and retention of candidates for science and technology positions in the executive branch based on the candidate’s knowledge, credentials, experience, and integrity;

In addition to consideration of candidates’ knowledge, credentials, experience, and integrity, IFT recommends that the selection process take into consideration personal references from universities and professional societies, as well as credentials of candidates’ involvement in their respective professional communities including any relevant accreditation by professional scientific and technical societies. Additionally, professional societies are valuable resources in identifying potential candidates for science and technology executive branch positions.

(b) Appropriate rules and procedures in each agency to ensure the integrity of the scientific process within the agency;

(c) Scientific and technological information considered in policy decisions should be subject to well‐established scientific processes, including peer review where appropriate, and each agency should appropriately and accurately reflect that information in complying with and applying relevant statutory standards; IFT has observed that the FDA/CFSAN generally bases its decision‐making on scientific data and rationale. IFT recommends that the Agency be encouraged to continue reliance on the scientific process and science in its decision‐making.

Executive branch agencies include peer‐review and public input in their decisionmaking processes as appropriate. IFT recommends that the executive branch also specifically seek scientific and technical input from pertinent professional scientific and technical societies. Scientific and technical societies have ready access to and actively leverage peer‐reviewed research of their members and can serve as authoritative voices in their respective fields.

(d) Except for information properly restricted from disclosure under procedures established in accordance with statue, regulation, Executive Order, or Presidential Memorandum, each agency should make available to the public the scientific or technological findings or conclusions considered or relied on in policy decisions;

IFT is a scientific society that is committed to the development and communication of science emanating from scholarly research through readily accessible peerreviewed publications. As such, IFT recommends that when decisions are made, the conclusions and rationale not only be made public but shared specifically with appropriate professional societies. Further, IFT recommends that the President encourage the agencies to duly consider disclosure of research findings that may be of particular value to industries and ultimately the public, but which are not necessarily so highly sensitive as to pose an undue risk upon restricted disclosure. For example, if a report on food‐defense were provided to a government agency, a summary that would not compromise national security might be considered for the benefit of food manufacturers to enable them to better protect the food system. Additionally, it appears that the FDA and the USDA classify some types of information that would not be classified by other agencies. To address this, IFT recommends that agencies not using the classification criteria of the Department of Defense be required to disclose their classification criteria.

(e) Each agency should have in place procedures to identify and address instances in which the scientific process or the integrity of scientific and technologic information may be compromised;

(f) Each agency should adopt such additional procedures, including any appropriate whistleblower protections, as are necessary to ensure the integrity of scientific and technological information and processes on which the agency relies in its decisionmaking or otherwise uses or prepares.

IFT appreciates this opportunity to provide some comments on scientific integrity.

Sincerely,

Sheri Schellhaass, Ph.D.
IFT President

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